Loose Tooth Industries, Inc. operates Fig.co (together with our affiliates, “Fig”, “we” or “us”), a technology platform available on https://www.fig.co/ (“Site”) that permits (i) prospective investors (“Investors”) to independently search and invest in investment opportunities (each, an “Investment Opportunity”) on the Site (ii) developers (“Campaign Owners”) to create a rewards campaign (each, a “Campaign”) to receive contributions and offer rewards (“Rewards”), and (iii) persons to support game development by contributing money to rewards campaigns (“Backers”) in exchange for a Reward. By accessing the Site or using the services, tools, applications and software provided through or in connection with the Site, including through a mobile device (the “Service”) in any manner, you become a Fig user (collectively, Investors, Campaign Owners and Backers are referred to as “Users”).
1. Personal Information We Collect
We may collect Personal Information about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the Service if that information is necessary to provide you with them or if we are legally required to collect that information.
1.1 Information Provided by You
Registration. You provide us Personal Information when you register to be a User:
- Your name;
- Your email address;
- Your username;
- Your password;
- Your Facebook information if you are signing up via Facebook connect (this will authenticate your identity and link your Facebook Profile information, such as your name, profile image, and email address, to your Fig account);
- You may provide your location and a profile image.
Campaign Owners. If you become a Campaign Owner in order to create a Campaign or administer one, you are asked to provide us with the following Personal Information in addition to the Personal Information you provide when you register to be a User:
- Your legal person or business name;
- Your legal physical address;
- Your Tax ID;
- Your telephone number;
- Your date of birth;
- Your PayPal account information (if accepting payments via PayPal);
- Your bank account information;
- An IRS tax withholding form (such as W-9, W-8 or W-8BEN).
Backers. As a Backer, you may provide us with the following Personal Information in addition to the Personal Information you provide when you register to be a User:
- Ship-to information;
- Your billing name and address;
- Your PayPal e-mail address.
Investors. If you become an Investor, you may provide us with the following Personal Information in addition to the Personal Information you provide when you register to be a User:
- Your legal physical address;
- Your telephone number;
- Your date of birth;
- Your business name, address, email and phone number, names of owners and management, if applicable;
- Balance sheets, profit and loss statements, bank account information, average bank balance, bank statement and other financial data, including tax returns, as applicable, in order to help verify your “Accredited Investor” or "Qualified Purchaser" status;
- tax ID number or social security number, as applicable, and citizenship status;
- responses to further questions answered during the profile creation.
Identity verification. You may be asked further information in order to help validate your identity:
- Your driver’s license information, government issued identification number;
- Other Personal Information as we need for verification;
User Content. We may collect any Personal Information you Post as User Content, which is available to the public. Copies may remain viewable in cached and archived pages or if other Users have copied or stored your User Content even if you remove the User Content. To request removal of your Personal Information from these areas of the Site, contact us using the information below. In some cases, we may not be able to remove your Personal Information, including for regulatory or compliance reasons, in which case we will let you know if we are unable to do so and why.
Messaging. The Site permits Users to communicate with other Users posting information on the Site. We may read, collect and analyze information transmitted between Users for regulatory compliance purposes. We do not guarantee that information provided by Site visitors is accurate or complete. Fig assumes no liability or responsibility for any errors or omissions in the content of this site, other than as required by law.
Communications. We may also collect Personal Information from you as a result of your email communications with us including your posts, our responses, the date and time of the inquiry and any other information you choose to submit to us.
Transaction Information. We may collect details of any requests or transactions you make through the Service. For Backers and Investors, we record your transaction information, including which Reward you selected or how many (and which) Fig Game Shares you are interested in, or have purchased.
Payment Information. All payment information you submit is collected and used by our payment processors in accordance with their privacy policies. Fig does not store your payment information apart from the last four digits of your account, expiration date, and country, which we require for tax, government regulatory, and security purposes.
Business Partners. If you work for one of our business partners or vendors, we will collect your contact details to manage the business relationship.
Job Application. If you apply for a job with us, we will collect your application information, including your resume and the contact details of your referees, as well as any other information you chose to provide to us in the context of your application.
1.2 Information Collected via Automated Means
Location Information. When you use the Service via a mobile device, we may collect your location information, provided that you have authorized us to do so via the mobile device operating system.
1.3 Information Provided by Third Parties
Social Sign-On. You can sign up for or sign in to your Fig account using Facebook Connect. When you sign in using Facebook Connect, Fig will receive the following information: your public profile and email address. Fig uses this info to authenticate your identity and link your Facebook Profile information to your Fig account. You can disconnect Facebook Connect by going to your Facebook app settings.
Our Partners. We may obtain address information about you from third party and public sources, including OnFido, VerifyInvestor and Computershare for fraud prevention, legal compliance or to provide the Services.
Other Users. As a Campaign Owner, you can invite others who are helping you with your campaign to join your campaign team. We will ask you for this person’s email address and send him or her an email invite to join your team. Fig collects this email address for the purpose of sending this invite. This person may contact us at firstname.lastname@example.org to request that we remove this information.
2. Use of Information
Purposes of the Processing. We may use your Personal Information in order to:
- operate and provide you with the Services, including to verify your identity and allow payment processing;
- communicate with you and respond to your inquiries, send you transaction and Service related emails, Campaign or User comment updates;
- analyze your preferences, interests and behavior in order to provide you with tailored content and the most relevant content and communications;
- send you marketing communications including offers, updates and promotions, and show you advertisements which may be tailored to you based on information such as the Fig games you are interested in or that you support, by email or through third party advertising platforms (e.g. Facebook, Twitter, Google, etc.);
- keep your account secure; protect our Site, Service and Users;
- analyze and improve our Site and the Service;
- to process your job application;
- manage our business relationships;
- for other purposes for which we provide specific notice at the time of the collection of the information
Legal Ground for the Processing. Where required under applicable law, we will only collect and process Personal Information about you if we can rely on a valid legal ground for that processing, such as consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Service you have requested)), legal obligations (e.g. for compliance with securities laws) and “legitimate interests” (e.g. for product development and analytics purposes).
If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us as described below.
3. Disclosure of Information
Fig entities. We may share Personal Information about you with our affiliates and subsidiaries.
Backers. As a Backer, we record your Reward selection in order to facilitate its delivery to you, when a Campaign is successful we deliver your contact information as well as Reward selection to the Campaign Owner so that they can deliver the Reward to you as well as follow up with surveys in order to facilitate delivery of Rewards. The Campaigns you have supported are visible to others on your profile page.
Campaign Owners. If you are a Campaign Owner, we may share your name, email address, and other contact information with any Backer for questions related to the Campaign or Rewards. Campaign Owners do not receive Backer’s bank or credit card information, but do have access to standard merchant information through these services.
Service Providers. We may share the information that you have provided us with certain trusted third-party services to help us provide, improve, promote, or protect the Services (including with payment processors, services to manage ads on other sites, and to analyze our Site’s functionality). Payment information you provide through our Site is processed directly through either Stripe or PayPal, as the case may be. We may provide such services with additional information that you have provided to us in order to help them or us verify the transaction.
Other Third Parties. As an Investor, we may share Personal Information about you with third parties, such as OnFido, VerifyInvestor, FundAmerica, HelloSign, and Computershare, in order to verify your status with respect to securities laws, facilitate your payment and any escrow of funds, to record your investment with our third party SEC-registered transfer agent and provide you with necessary tax reporting information.
We may also share information that is aggregated and anonymized in a way so that it does not directly identify you.
Fig does not and will not sell any of your Personal Information to any third party for purposes of advertising, soliciting, or telemarketing. We may, however, disclose your Personal Information to other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock. In that case your Personal Information may be sold or transferred to the potential or actual acquirer, successor, or assign.
4. Your Rights and Choices
Marketing. We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by contacting us using our contact form on help.fig.co or you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails.
Please note that opt-out requests may take up to one week to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.
Location Information. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.
Other choices. You are able to access, update and modify the information concerning your account by visiting your Profile page and editing any information in your Profile. You are able to change your e-mail address, password, contact information, privacy settings or other login information by visiting your account’s settings page. If you wish to suspend your account or need help modifying account information, including changing your status as an “Accredited Investor” or "Qualified Purchaser", please contact us using our contact form on help.fig.co.
If you would like us to remove, or provide additional access to, any Personal Information from our database, please send a request via our contact form on help.fig.co and we will do so or you will receive a response within one month.
European Users. If you are located in the European Economic Area or Switzerland, you may have the right to:
- Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
- Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below.
5. Unsolicited Idea Submissions and Pitches
We are always pleased to hear from you, and welcome your comments, suggestions or game pitches. However, products, services, and features developed by Fig or its developers might be similar or even identical to a submission received by us. When we refer to a “submission” in this paragraph, we mean: any submission, pitch, comment, or suggestion (including, but not limited to, ideas, products, or services and suggested changes) made either on the Site or to us about an existing product or service on, or a feature of, or a proposed addition to, the Site or a game (including a pitch for a new game idea).
With regard to submissions and pitches:
(1) all such submissions are non-confidential and non-proprietary and will be treated as non-confidential and non-proprietary;
(2) we and our Users and developers will have no express or implied obligation or liability of any kind concerning the submissions, including, for example, any use or disclosure of the submissions; and,
(3) we and our Users and developers are entitled to unrestricted use or disclosure of the submissions for any purpose whatsoever, all without compensation to the User that submitted the submission.
6. Data Transfers
Since Fig is based in the United States, your Personal Information will be collected and processed in the United States. The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country.
7. Links to Other Websites, Blogs/Forums and Social Media Widgets
Our Site includes links to other websites whose privacy practices may differ from those of Fig. When you use a link to go from our Site to another website, such as that of our payments processors, the privacy statement for the other website governs. We encourage you to carefully read and understand the privacy statement of any website you visit.
Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be displayed publicly and read, collected, and used by others who access them. To request removal of your Personal Information from our blog, contact us at email@example.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
8. Security and Data Retention
Security. The security of your Personal Information is important to us. We follow generally accepted standards and have implemented security measures we believe to be appropriate in order to protect the Personal Information we collect, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org.
We use Security Sockets Layer (SSL) encryption technology to encrypt Personal Information (such as your payment information) before it travels over the internet. Credit card numbers are never stored on our database or servers.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer.
We will promptly notify those persons whose Personal Information is compromised. Notwithstanding, Fig does not accept liability for any unintentional disclosure or a disclosure that occurs due to a security breach of our systems or facilities.
Data Retention. When determining the retention periods, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
The Site is not intended for use by children. No one under eighteen (18) years of age is allowed to use the Site, provide any Personal Information or receive our email distributions. We do not knowingly solicit or collect Personal Information from anyone under eighteen (18) years of age. If you believe that a minor has disclosed personally identifiable information to Fig, please report this to us immediately by contacting us via our contact form on help.fig.co.
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