Flock Privacy Policy

The Flock mobile application (the “Application”) is brought to you by What The Flock LLC (“Flock”, “we” or “us”). The Application provides you ( “you, “User”) an opportunity to connect with other users to discuss and recommend books to one another. One of our priorities is the privacy of our Users. This Privacy Policy contains detailed information about regarding the information we collect, share, and use through the Application (collectively, the “Services”), the manner in which we may use such information, how we protect it, and the choices available to you regarding our use of your personal information.

Your use of the Application is also governed by the Flock Terms and Conditions (the “Terms and Conditions”). Please consult the Terms and Conditions for more detailed information about the Application and the Services. Capitalized terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms and Conditions. This Privacy Policy is only applicable to the information Users share and/or collect on the Application. It is not applicable to any data gathered offline or via channels other than the Application. Our Privacy Policy was created with respect to all the necessary compliances required to adhere to consumer information collection and business operation commencement in the United States.

We may modify, update or supplement our Privacy Policy from time to time. Any changes to this Privacy Policy will be posted on this page. You are advised to review this Privacy Policy often for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or if you are aware that any personal data, we hold is inaccurate.

This Privacy Policy is binding on all those who access, visit, and/or use the Application whether acting as an individual or on behalf of an entity.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we treat it in connection with the Application and the Services. If you do not agree with this Privacy Policy, you should not use or register with the Application, and instead you should un-install it.

1. Information Collected Through the Application

“Personal Information” means information that allows someone to identify or contact you, including, for example, your name and phone number, as well as any other information about you that is associated with or linked to any of the foregoing data or other information that can be used to identify or contact you. “Anonymous Information” means data that is not reasonably linked to your Personal Information. Anonymous Information is created by manipulating or removing the reasonable link to personal identifiers. We collect Personal Information and Anonymous Information through the Application, as described below. As used herein, the term “Information” means both Personal Information and Anonymous Information.

a. Information You Provide to Us

i. Account and Profile Information: We may collect Information from you, such as your name, birthdate and phone number, as well as any other information that could be used to identify or contact you and Application passwords, when you are requested and provide this Information in the Application, including when you register and create an account for the Application’s Services (your App Account), as required to use the Application.

ii. Feedback Information: If you provide us feedback or contact us via e-mail through the Application, we will collect your name and email address, as well as any other content included in the e-mail, in order to send you a reply. Feedback or questions regarding support on the Application can be sent to hello@onflock.com.

iii. We may also collect other Personal Information for the provision of our Services on the Application that state that Personal Information is being collected, such as requests for your e-mail made through the Services.

b. Information Collected via Technology.

To make the Services more useful to you, the Services use technology to automatically collect certain Information, including but not limited to:

i. Usage details: The Services may automatically collect certain details of your access to and use of the Services, including traffic data, engagement with advertisements, clickstream information (which is the recording of the parts of the screen or Application that you click on), and date and time of usage/visit.

ii. Device information: The Services may collect Information about your mobile device, including the unique advertising identifier (Ad ID) of the device, IP address, operating system, browser type, domain type, mobile network information, the device’s manufacturer and model information and a list of the applications on the device.

c. Information Collected by or Shared With Third Parties

i. Third parties will not be able to collect any Information from you through your use of the Application. “Third Parties” means any parties that are not Flock, which may include, but is not limited to: survey providers, and analytics companies. We may, however, share other Information with the Third Parties, such as your profile information collected by the Application. However, the Third Parties are not bound by this Privacy Policy and may use the Information for any lawful purposes. Our Application does not allow Third Parties to collect your Information while using the Application, but should you engage in links, ads, or other items on the Application that takes you to another application or website, Third Parties may collect other Information about you outside of the Application, such as your online activities over time and across different websites and applications. Flock is not responsible for the information collected directly by the Third Parties or their privacy policies or practices.

2. How Information Collected Through the Application Is Used

a. General Use

In general, Information you submit to us or that is collected by us in connection with the Application or the Services is used either to respond to requests that you make, or to aid us in serving you better. We may use your Information in the following ways:

i. To provide you with the Application and the Services.

ii. Fulfill any other purpose for which you provide it.

iii. To share with Third Parties.

iv. To facilitate the creation of and secure your App Account on the Application and recognize you when you use the Application.

v. To notify you when Application updates are available, and of changes to the Application or Services.

vi. To analyze use of the Application.

vii. To monitor the Application and the Services for fraud, abuse or violations of the Terms and Conditions.

viii. To improve and deliver a better and more personalized experience through the Application.

b. Creation of Anonymous Information

We reserve the right to use Anonymous Information for any purpose and disclose Anonymous Information to Third Parties in our sole discretion. We may create Anonymous Information records from Personal Information by removing or manipulating information that makes the data personally identifiable to you. We use Anonymous Information to analyze usage patterns of the Application and to enhance the content of our Services and improve the Application.

3. How Information Collected Through the Application is Shared

We may disclose your Information as described below and as described in this Privacy Policy.

a. Third Party Service Providers

We may share your Information with third party service providers who help support the Application, the Services or our business.

b. With Consent

We share your Information for any other purpose disclosed by us at the time you provide the Information.

c. Affiliates and Acquisitions

We may share your Information with any of our affiliates, in which case we will require our affiliates to honor this Privacy Policy. We may also share your Information if we undergo a merger or sale transaction.

d. Anonymous Information

We may use or disclose Anonymous Information without restriction.

e. Other Disclosures

Regardless of any choices you make regarding your Personal Information, we may disclose Personal Information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, court orders, warrants served on us or legal process, including responding to any government or regulatory request; (c) to protect or defend our rights or our property or the users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms and Conditions.

4. Third Party Websites and Applications

When you click on a link or otherwise leave our Services and go to another site, another entity may collect Personal Information or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links or swipe left to connect to such outside websites.

5. COPPA

In accordance with the Children’s Online Privacy Protection Act (“COPPA”), the Application is not directed or targeted at any individuals under 13 years of age, and the Application does not knowingly collect Personal Information from such individuals. No one under age 13 may provide any Personal Information to Flock. If we later obtain actual knowledge that a User is under 13 years of age, we will take steps to remove that User’s Personal Information from our systems and delete the Account. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at hello@onflock.com so that we may delete and remove such information from our systems.

6. Opting Out

We understand that you may not wish to have your Information collected and used to receive interest-based ads or content on the Application. You may prevent your device’s Ad ID from being collected by changing the related settings on your device. On iOS, you may find and edit this setting on the Settings application on your device. Through Android, this setting can be accessing through the Google Settings application, selecting the Application, and opting out of collection of Ad ID. Doing so may also affect your experience with the Services.

7. Updating Your Profile or Account Information

You can change your profile or App Account Information (other than your phone number) in the App by editing it.

8. Security of Personal Information

We take reasonable security safeguards such as firewalls, data encryption, authorization controls, and other security measures to protect you against such risks as loss or unauthorized access, destruction, use, modification, or disclosure of Personal Information.

You should not provide your App Account information to unauthorized parties. You are encouraged to protect your mobile device and passwords against unauthorized access.

9. Communication Preferences

We may send you e-mails to promote the use of the Services. When you receive those e-mails, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, by terminating your App Account or by contacting us directly at hello@onflock.com.

These choices do not apply to the display of online advertising or the receipt of mandatory service communications that are considered part of the Services, which you may receive periodically unless you close your App Account.

10. Use of Cookies and Other Technologies

We may use technologies, such as cookies, advertising identifiers (such as the Android Advertising ID) and web beacons, to collect, store and read Information as described in this Privacy Policy on your mobile device when using the Services. Cookies are small chunks of data created by a web server, delivered through a web browser, and stored on your device. They provide a means for mobile applications that you use or visit to keep track of your usage patterns and preferences, as well as to identify you as a return visitor. Cookies make the personalization of your mobile application possible, so that you do not need to re-enter information from scratch upon each visit.

Please note that if you take steps to block cookies, doing so may impact the Services or prevent certain elements of the Services from functioning.

11. Changes to This Privacy Policy

We may occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the effective date at the top of this Privacy Policy. If there are material changes to this Privacy Policy, we will notify you by prominently by email. We encourage you to review this Privacy Policy to be kept informed about our privacy practices for the Services. Continued use of the Services, following notice of such changes, shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

12. GDPR Privacy Rights

This Application is for use by individuals in the US only, however, please note the following rights and guidelines defined under the General Data Protection Regulation (the “GDPR”). Every user is entitled to the following information.

• The right to access – You have the right to request copies of all your personal information stored with tgin. We may charge you a small fee for rendering the service.

• The right to rectification – You have the right to request that we make corrections to any information you believe is incorrect, inaccurate, or incomplete.

• The right to erasure – You have the right to request that we completely delete all your personal information, however, under certain defined conditions.

• The right to restrict processing – You have the right to request that we restrict the processing of your personal information, however, under certain defined conditions only.

• The right to object to processing – You have all the right to object to us processing any of your personal information, however, under certain defined conditions.

• The right to data portability – You havethe right to request that we transfer the information we have collected from you to another organization, or directly to you, however, under certain defined conditions.

To the extent applicable, if you would like to exercise any of the above-mentioned rights, under any circumstances, please contact hello@onflock.com.In order to comply with such requests, we may require additional information from you in order to confirm your identity.

13. US State Privacy Rights

Under some U.S. state laws residents may have the rights listed below:

• Right to Know : The right to request the Personal Information that we collect, uses or discloses and information about our data practices;

• Right to Request Deletion : The right to request that we delete the Personal Information we have collected about a user;

• Right to Opt-Out of Data Sales: The right to restrict the sale to third parties of a user’s Personal Information that we have collected;

• Right to Non-Discrimination : The right to not be discriminated against for exercising any of these rights;

• Right to Correct Information: The right to update or correct the Personal Information that we collect;

• Right to Limit Use or Disclosure of Sensitive Personal Information: The right to limit the use and disclosure of Sensitive Personal Information (as defined under the CPRA);

• Right to Access Information Related to Automated Decision Making: The right to inquire about our logic involved in automated decision-making applied to personal data we collect; and

• Right to Opt-Out of Automated Decision-Making Technology: The right to request a user’s removal from having automated decision-making applied to a user’s personal data that we collect.

To request further information pursuant to a user’s “right to know” or to request deletion of personal data pursuant to the user’s “right to request deletion”, please contact us at hello@onflock.com.

Only a user or an authorized agent may make a request related to such user’s Personal Data. Note that to respond to a user’s requests to access or delete personal data as outlined in applicable state laws, we must verify the user’s identity.

California’s Shine the Light Law:

California Civil Code Section 1798.83 permits the users of the Application who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their 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.

If you are a California resident and would like to make such a request, please submit your request in writing to hello@onflock.com.

Only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests, we must verify your identity and reserve the right to confirm your state residency.

14. Transfer of Information

Your information, including personal information, may be transferred to and maintained on computers outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

15. Contacting Us

If you have questions about this Privacy Policy, please contact us at hello@onflock.com.