Effective Date: March 30, 2022 This document is the Findd Privacy Policy, which describes what information we collect from you and how we use it. Our Privacy Policy applies to our websites (www.findd.io and app.findd.io, collectively, the “Website”), our mobile applications (the “Mobile Application”), our Grandd Central online application and cloud service (“Grandd Central”), and all other related services (collectively with the Website, the Mobile Application, and Grandd Central, the “Findd Services”). This policy Covers “Personal Information,” which means information that can or potentially can be used on its own or with other information to de-anonymize data or to identify, contact, or locate a single person. Personal Information (“PI”) includes data such as your name, email address, phone number, mobile device’s unique identifier, facial geometry and other biometric identifiers, among other things. Findd reserves the right to change this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes. By continuing to use our services, you accept those changes and agree to be bound by the updated policy. Please contact us at info@findd.io if you have any questions about this Privacy Policy.

1. We Collect Information to Provide You with Findd Services

We are committed to only collecting the information necessary to provide and improve Findd Services. When we do collect your information, we store it and associate it with your account unless otherwise noted. We take your privacy very seriously and will only use and disclose this information as described in this Privacy Policy. Note that some of our products collect only limited information or no information at all. Not every section of this Privacy Policy will apply to these products.

2. Information Findd Collects

• 2.1 Registration Information
  To create an account, you must provide your email address and a password.
•  2.2 Credit Card Information
  If you purchase a Findd Service directly from us, we may collect your credit card number, expiration date, security code and other applicable billing information. We use this information to bill you for services. Findd uses third-party payment processors and therefore has only limited information about your payment transactions.
•  2.3 Device Information
  When you use Findd Services on a mobile device, our servers automatically record certain information about your mobile device. This information may include an equipment identifier (e.g., IMEI, UDID), subscriber identifier (e.g., IMSI), device name, mobile phone number, device type and manufacturer, operating system type and version, wireless carrier/operator, network type, country of origin, Internet Protocol (“IP”) address, and the dates and times of your requests. We use this information to provide our services, and support if needed.
•  2.4 Social Media Features
  Our Website includes social media Features (“Features”), like the Facebook recommend button or interactive mini-programs that run on our site. If you use these Features, they will collect your IP address, which page you are visiting on our site, and set a cookie to enable the Feature to function properly. Features may be hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing the Feature, not by Findd’s Privacy Policy.
•  2.5 Information About Your Use of Findd Services on Your Phone
  We use analytics software so that we can improve the features and usability of our products. This software may analyze information such as how often you use the Mobile Application, the events that occur within the Mobile Application, and where the Mobile Application was downloaded. We may also use such information to show you relevant content and suggest new features, products and services that can enhance your use of the Findd Service. We do not link the information we store within the analytics software to any personally identifiable information you submit within the Mobile Application.
•  2.6 Information About Your Use of Findd’s Website and Emails
  We use analytics services to measure how people use our Website and emails so that we can improve our products and services and provide more relevant content to you. Analytics services may work by embedding invisible images that are associated with unique identifiers on our site, by using cookies or other local device storage or by using web beacons, web bugs, clear gifs, and similar tracking technologies.
•  2.7 Premium Content & Promotions
  We may ask for your email address and other contact information in order to allow you to access various Findd content, such as whitepapers, videos, or other research materials, to participate in surveys, contests, promotions, or sweepstakes, or to obtain additional information about Findd services and products. We will use this information to provide you with additional information on products and services from Findd or our business partners, which might be of interest to you. You can choose not to receive such marketing communications by clicking on the unsubscribe link in our emails, as further described below.
•  2.8 Location Information
  Some features we offer work better if we know where you are. Findd may collect location information in two ways. We may receive it directly from your mobile device, or, in some situations, we may receive location data from cell tower or Wi-Fi hotspot information. We may use third-party service providers to translate that information into usable location information.
•  2.9 Photos and Other Camera Data
  Our Mobile Application uses the camera as part of our facial recognition functionality and captures images of the user as part of the features the Findd Services offer. These images are only captured when the user initiates the capture. They are then stored locally and uploaded to our secure online storage facilities as part of the Findd Services.
•  2.10 Biometric Identifiers
  To use certain features of the Findd Services, you may be required to provide photographs from which we will collect information about your facial geometry or other Biometric Data. We will not collect or store your Biometric Data without informing that we are doing so and requesting your consent.
  • For purposes of this Privacy Policy, “Biometric Data” means your biometric identifiers (such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry) or any information based such biometric identifier(s) and used to identify you.
•  2.11 Other Information You Provide to Us
  To the extent you use our products or services to voluntarily provide us with any other information, we may collect such information and use it for the purposes for which you provided such information, or as otherwise provided in this Privacy Policy. We also collect information as described elsewhere in this Privacy Policy.

3. What You Should Know About Specific Products

This section provides additional information about specific services and features that are part of the Findd Services. The information is used as described in this section and in the section entitled “How We Use the Information We Collect” below.

•  3.1 Mobile Application
  • 3.1.1 What types of user information does the Mobile Application collect?
    • Precise Location (GPS and network-based). The Mobile Application captures location details and information, including GPS coordinates, from your mobile device. We use this information to record your locations when you use the Mobile Application to punch in.
    • Photos and Videos. The Mobile Application accesses and utilizes mobile devices’ camera(s) to capture the facial geometry and other Biometric Data of the person using the Mobile Application to punch in.
    • Bluetooth Access. The Mobile Application uses mobile devices’ Bluetooth settings to detect beacons that are part of our geofencing features to determine a user’s location. Beacons are set up and registered by employers for use with their accounts.

• • 3.1.2 How is this information used?
    • Location Data.
      The location information we collect is uploaded to Grandd Central cloud solution and stored for use in geofencing features and other location-based features of the Findd Service. The Mobile Application only captures location information when initiated by the user while using the Mobile Application.

• • • Photos and Videos.
      Images we collect are stored locally and uploaded to Grandd Central and stored for use in timekeeping features accessible by employer accounts. The Mobile Application only captures images from the device when initiated by the user while using the Mobile Application.

• 3.2 Grandd Central
  • 3.2.1 What types of user information does Grandd Central collect?
    • Account information. This includes contact information such as name, address, phone number, and email address.
    • Facial geometry and other Biometric Data. Photos of those who use the system are stored in Grandd Central representing their individual punch records and face recognition Biometric Data.
    • Location data. We store the location record (including GPS) associated with each punch uploaded from the user’s device when available.
  •  3.2.2 How is this information used?
    We use the data collected in Grandd Central in order to provide the features of the Findd Services related to time tracking and geofencing. The photos and locations of individuals using the system are displayed as part of the Findd Service feature used in tracking time and location for a company’s workers. When requested by our employer clients, we may integrate this date with the employer’s time and attendance systems and/or payroll systems.

4. Cookie Policy 

• 4.1 Types of Cookies
  Like many online services, we use cookies and other tools to collect and analyze information about you and your usage of our products and services. We also use these technologies to deliver content for relevant Findd products and services. Cookies are small data files that we store on your computers or device. For details, see aboutcookies.org.
• 4.2 How We Use Cookies
  We use “session” cookies to keep you logged in while you use the Findd Service, to better understand how you interact with the Findd Service, and to monitor aggregate usage and web traffic information on the Findd Service. Session cookies disappear when you logout of the Findd Service and/or close your web browser. We also use “persistent” cookies to recognize you when you return to the Findd Service. Persistent cookies can stay on your computer for a longer period of time than session cookies do. We also use “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Findd Service and how they’re using it. This helps us to improve the way our Website works, for example by making sure users are finding what they need easily. Finally, we may use other standard technologies, such as web beacons, web bugs, clear gifs, and local storage, to analyze, collect and aggregate data about your use of our products and services.
• 4.3 Cookies From Third-Parties
  We believe it is important for you to know exactly what third-party cookies we use on our Website and the Findd Service. Here is a list of the third-party cookies that we currently use. As we develop and improve our services, we may use other third parties that are not listed below.
  • 4.3.1 Google Analytics.
    These cookies allow us to see how you use our Website and Mobile Application so that we can improve your experience. We encourage you to read the Google Privacy Policy. If you don’t want data reported by Google Analytics, Google permits you to opt-out by installing the Google Analytics Opt-out Browser Add-on.
  • 4.3.2 Google AdWords.
    These cookies allow our vendors to serve ads based on your past visits to our sites and for remarketing purposes. Google may use this cookie and other tracking technology to show you our ads across the internet. Google permits you to opt-out of Google’s use of these cookies by visiting Google’s Ads Settings.
  • 4.3.3 Social Media Features.
    Our Website includes social media features, like the Facebook recommend button or interactive mini-programs that run on our site. If you use these Features, they will collect your IP address, which page you are visiting on our site, and set a cookie to enable the feature to function properly. Features may be hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by Findd’s Privacy Policy.

5. How We Use the Information We Collect

In addition to the specific uses described above, we also use your information in the following manner:

• 5.1 We Use Your Information to Provide, Improve, and Promote Our Services.
  We use your information to provide you with a better service, to improve our products and services, to promote our services and to develop new services. For example:
  • If you fill out a survey or email Findd for support, we may retain that information in order to provide you with support and to improve our services.
  • We may send text messages to your phone to communicate with your device.
  • We may use your email address or mobile number to send privacy or security-related notices and notify you of major Findd Service changes.
  • We may use your email address or mobile phone number to communicate about product announcements and special promotions from Findd or our business partners, or to administer participation in special events, surveys, contests and sweepstakes.
  • We may use your information to conduct market research and engage in joint promotional activities with companies that have products that can add value to Findd products or services (for example, with mobile operators).
• 5.2 We May Disclose Your Information in Accordance with the Law
  Like other companies, we may disclose your information consistent with the law to, for example: (i) comply with a law, regulation, or legal process (including to meet national security or law enforcement requirements); (ii) protect the safety or security of any person, entity or facility; (iii) address potential violations of our Privacy Policy or Terms of Service; (iv) investigate fraud, security, or technical issues; or (v) protect Findd’s or a third party’s rights or property, our employees, users, and the public. We strongly believe that you have a right to know if we are required by law to disclose your information. As such, before we disclose your Information in response to a law enforcement request (for example, a subpoena or court order), we will notify you at the email listed in your account, unless (a) we are prohibited from doing so or (b) in emergency cases where notice could create a risk of injury or death, or the case involves potential harm to minors. Furthermore, nothing in this Privacy Policy is meant to limit any legal defenses or objections that you may have to a third party’s, including the government’s, request to disclose your information.
• 5.3 We Share Your Information to Provide or Improve Our Services
  We share your information with third parties to provide or improve our services. For example:
  • We may share your information with third-party service providers of products and services integrated with our software that need to know your information to fulfill your product or service requests (for example, to map your location or send you an SMS), support our products and services, or analyze data for product performance and product improvement purposes.
  • We may share your information to perform accounting, auditing, billing reconciliation, and collection activities.
  • We may share your information with our affiliates, resellers or other third-party service providers that are working with Findd to ensure proper delivery of your purchase and related support services, perform business-related functions, and provide you with information about products and services.
  • If your use of the Findd Service requires you to provide Biometric Data (such as facial geometry), we may share that information with your employer.
•  5.4 We Share Data That is Aggregated and De-Identified
  We share de-identified or aggregated data publicly and with our partners and other third parties.
•  5.5 We May Disclose Your Information With Your Consent
  We may also share your personal information with third parties when we have your consent to do so.

6. Data Retention Policy

• 6.1 General
  Our policy is to retain personally identifiable information only as long as reasonably necessary to provide our products and services to you and others or as otherwise required for legal compliance purposes. We may delete your data if your account is inactive and as otherwise provided in our Terms of Service.
• 6.2 Biometric Data
  Notwithstanding the foregoing, we will permanently destroy all of your Biometric Data that we collect or store (a) when our initial purpose for collecting or obtaining your Biometric Data has been satisfied, or (b) three years after your last interaction with Findd, whichever comes first.

7. Information Posted to Our Blog and Community Forum Is Public

If you comment on our blog or other public forums, you should be aware that any information you submit there can be read, collected, or used by other users of those blogs, and could be used to send you unsolicited messages. We are not responsible for the information you choose to submit in these blogs or for any content you receive as a result of sharing such information. To request the removal of your personal information from our blog or community forum, contact us at info@findd.io. If we are not able to remove your personal information, we will let you know why.

8. We Take Security Seriously

Securing your data is important to us. Findd uses commercially reasonable physical, managerial, and technical safeguards. For example, we use a combination of firewalls, authentication, physical security, and other safeguards to protect your account and your data. When you enter sensitive information (such as credit card number or location-based information) on our Website, within the Mobile App, or in our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Because no method of transmission over the Internet or method of electronic storage is 100% secure, we cannot ensure or warrant the security of any information, data, or content that Findd receives on your behalf to operate the Findd Service, or that you transmit to Findd. All such receipt or transmission of your information is at your own risk. We cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If Findd learns of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

9. You Are Responsible for Maintaining the Accuracy and Confidentiality of Your Email Address and Password

You are responsible for maintaining the secrecy of your password and other login information at all times. We recommend that you use a strong password that you do not use with other solutions. If you believe your password has been compromised, please change your password immediately via the Website, or contact us at info@findd.io for assistance. You are responsible for ensuring that the email address associated with your account is accurate and up to date. We use that email to contact you about updates, changes to our policies, and account activities such as requests for your information. Findd is not responsible for personal data transmitted to a third party as a result of a user’s providing an incorrect email address.

10. We Are Not Responsible for Content on Third-Party Websites

Our site contains links to other websites. When you click on one of these links, you leave Findd’s Website and go elsewhere. Findd does not accept liability for misuse of any information by any website controller to which we may link. We encourage you to read the privacy statements of these linked sites, which may differ from ours. In addition, if you take advantage of an offer from one of our partners, you may be providing information directly to that partner. We encourage you to review the privacy statements of these partners, as we are not responsible for the privacy practices of any partners or linked sites.

11. This Privacy Policy Will Apply Upon Change in Control

In the event that Findd is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your information may be sold or transferred as part of that transaction.

12. We Post Updates on Our Website Whenever This Policy Changes

This Privacy Policy may be revised to keep pace with changes in our products and services and laws applicable to Findd and you. If we make material changes to this policy, then we will notify you in our Mobile Application, here on this Website, by email, or by means of a notice on the Findd home page. Please note that your continued use of our services means that you agree with, and consent to be bound by, the new Privacy Policy. If you do not wish your information to be subject to the revised Privacy Policy, you will need to close your account.

13. Contact Us if You Have Any Questions or Concerns

Please contact us at info@findd.io with any questions or comments about this privacy policy.

Policy effective as of March 30, 2022.