Privacy Policy

Last Updated: June 30, 2020

This Privacy Policy of Feello, Inc. (this “Privacy Policy”) explains how information about you is collected, used and disclosed by Feello, Inc. and its subsidiaries and affiliated companies (“Feello”). This Privacy Policy applies to information we collect when you use our website, mobile application and other online products and services (collectively, the “Services”).

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Collection of Information

Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect includes information such as your name, address, phone number, email and details around a potential transaction and any other information you choose to provide.

Information We May Collect Automatically When You Use the Services. When you access or use our Services, we automatically collect information about you, including:

Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
Location Information: We may collect information about the location of your device [each time you access or use one of our mobile applications or otherwise consent to the collection of this information. For more details, please see “Your Choices” below.
Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers and publicly available sources if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

We may use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices,
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Communicate with you about products, services, offers, promotions, rewards, and events offered by Feello and others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage and activities in connection with our Services;
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Feello and others;
Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
With third parties for their own services and marketing purposes, unless you opt out of this type of sharing as discussed below;
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Feello or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
Between and among Feello and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button). Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Feello and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. This Privacy Policy will be updated to include specific instructions on how to opt out of such analytics services if and when we begin allowing others to provide such services. Your mobile device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

We may also work with other websites or platforms (such as Facebook) to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way. To opt out, please change the appropriate settings in the Privacy Policies page of your account with Feello.

Security

Feello takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Children Under the Age of 13

Feello will not knowingly collect personally identifiable information from any person under the age of 13. The Services are not designed to attract the attention of persons under the age of 13.

Mapping Services

Mapping services provided through Feello websites are the property of the respective indicated providers and subject to the usage policies of each such provider.

Transfer of Information to the U.S. and Other Countries

Feello is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.

In the event Feello transfers personal data from the EU to the U.S., Feello will comply with the EU-U.S. Privacy Shield Framework with respect to that data. For more information about the EU-U.S. Privacy Shield Framework program, please visit https://www.privacyshield.gov/Program-Overview. If you have questions about our compliance with the Safe Harbor program, you should contact us at privacy@feello.com.

Your Choices

Account Information. You may update, correct or delete information about you at any time by logging into your online account or emailing us at privacy@feello.com. If you wish to delete or deactivate your account, please email us at privacy@feello.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Opting Out. To opt out of sharing of personal information with third parties by Feello, please navigate to the Privacy Policies page of your account with Feello and change the appropriate setting. Feello’s third-party ad servers, ad network providers, and third-party advertisers (the “Feello Ad Providers”) may provide you with advertisements that you may see on the Services or on other affiliated websites. To improve the relevancy and help measure the effectiveness of such advertisements, the Feello Ad Providers may use cookies, Web beacons, clear .gifs or similar technologies. These are used to record users’ activity, such as the pages visited, and to learn what types of information are of most interest to the users. If you do not want Feello and its marketing services providers to follow your usage of our Services via cookies and Web beacons, you can opt out of Cookies/Web beacons from the Privacy Policies page of your account with Feello. Opting out of these services does not mean you will no longer receive online advertising. It does mean that the service from which you opted out will no longer deliver ads tailored to your Web preferences and usage patterns. Please note that, if you opt out and later delete your cookies, use a different browser, or use a different computer or other electronic device, you will need to renew your opt-out choices.

Location Information. When you first launch any of our mobile applications that collect location information, you will be asked to consent to the application’s collection of this information. We currently require this location information in order to use our Services most effectively, so if you do not consent to this collection, you cannot use our Services as they were originally intended. If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our mobile applications, or certain features thereof, will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove all of our mobile applications from your device.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications. You may opt out of receiving promotional emails or text messages from Feello by following the instructions in those emails or text messages or by following the procedures outlined above in the section of this Privacy Policy entitled “Opting Out”. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your California Privacy Rights. California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at 701 N. 36^th Street, Suite 320, Seattle, WA 98103, privacy@feello.com or (206) 905-4900. Please also refer to the attached Appendix A for more information.

Contacting Feello

You can access, update, and delete personal information you provide to Feello in your account profile by logging into your account or emailing us at privacy@feello.com for accounts on Feello, Inc. Please be aware that cannot always delete records due to financial reporting, compliance, or other reasons.

If you have any questions about this privacy statement, or the privacy practices of Feello, please email us at privacy@feello.com.

Appendix A

CCPA Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Feello, Inc. (“Feello”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the Feello website or subscribe to receive the Feello services (collectively, our “Services”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category A – Identifiers

Examples: Name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.

Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.

Category C – Protected classification characteristics under California or federal law

Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.

Category D – Commercial information

Examples: Records of personal property.

Category F – Internet or other similar network activity

Examples: Access history and information on your interaction with our application.

Category I – Professional or employment-related information

Examples: Occupation, employer information.

Category J – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Examples: Education level, school attended.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our Services.
Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, to submit this information to our clients or their agents in the form of insurance application forms or request for information.
To provide you with email alerts and other notices concerning our Services, or updates to your insurance application process.
To improve our Services to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category J: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

Our clients or their agents for which you have engaged in a business contract.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at CCPA@Feello.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you use of our Services.
Provide you a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Feello website and this Privacy Notice to check for any changes.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at Privacy@Feello.com