FIGGS.AI PRIVACY POLICY
Last Updated: March 21, 2024
This privacy policy (“Privacy Policy”) governs how Figgs.ai (“Figgs.ai”, “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you
(“you”) in connection with https://www.figgs.ai/ (the “Website”) or Figgs.ai mobile application and any other mobile software application, that we license (the “App”;
collectively, the “Platform”), such as in the following use cases:
(i) When you browse or visit our Website;
(ii) When you download our App
(iii) When you make use of, or interact with, our Platform:
a. When you create an account and when you log in
b. When you contact us (e.g. customer support, need help, submit a request)
c. When you subscribe to our distribution list(s) / newsletter(s) / blog(s) / social community(s)
(iv) When we process your Input (As defined in our Terms of Use) to create Outputs (As defined in our Terms of Use) and/or you use the related features on the
Platform
a. When you create your Fig (bot) and/or multiplayer (multiple bot or multiple user) scenes
b. When you chat or interact with our services
(v) When you engage with social features on our Platform (e.g., like, comment, follow/subscribe)
(vi) When you interact with us on our social media profiles (e.g., Reddit, Discord, Facebook, Instagram, Twitter/X, TikTok)
Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means
any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable
Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal
basis in the table below is only relevant to GDPR-protected. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including
your rights to a remedy or means of enforcement.
Table of contents:
1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights
6. Use by children
7. Interaction with third-party products
8. Analytic tools
9. Specific provisions applicable under California privacy law
10. Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement
significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Platform or
by other means. The Platform is owned and operated by Decart Ai, Inc., which is the data controller.
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Specific Personal Data we
collect
Why is Personal Data collected and for what
purposes?
Legal basis (GDPR only, if
applicable)
Third parties with whom we share
your Personal Data
Consequences
of not
providing the
Personal Data
When you browse or visit our Website
Cookies, analytic tools, and
log files
For more information, please
read our cookies policy
● Marketing (including evaluation of
success of our advertising campaigns)
● Analytics & Statistics (including
regarding which parts of the Platform
are more popular)
● Bug Fixes and Improvements for the
Platform
Consent
Legitimate Interest (e.g., essential
cookies)
3
rd
party platforms such as for the
following purposes:
Analytics Tools
Certain
non-essential
Website
features may
not be available
Read more
about the
purposes of
each cookie
here [please read our
cookies policy]
When you download our App
Data collected by default
when downloading an app
from the Apple App Store or
Google Play Store
● Compliance with the guidelines of the
Apple App Store and Google Play
Store
● Analytics & Statistics
Consent
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
3
rd
party platforms such as for the
following purposes:
Information may be processed by
Apple and Google through interactions
between the Platform and their
respective stores. It may be the case
that the phone manufacturer (for
example, Samsung) will also have
access to this data.
Cannot
download or
use the App
When you make use of, or interact with, our Platform
(a) When you create an account and when you log in
● Full name
● Nickname
● Age
● Gender
● Country
● Email address
● Phone Number
● Password
● OAuth (or similar) access
tokens
● To be able to create an account
● To be able to log in
● To be able to enjoy features available to
registered users only
Legitimate interest (e.g. to
provide you with the Platform)
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
3
rd
party platforms such as for the
following purposes:
In the case that the Platform allows
and/or requires signup and/or signin
via services using OAuth (or similar),
then the 3
rd
party providing the service
(for example, Google) may also have
access to the data.
In the case that the Platform allows
and/or requires phone number or email
verification, then 3
rd
party providers
Cannot create
an account
Cannot log in
Cannot enjoy
all the features
of the Platform
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may be used in order to perform this
verification.
(b) When you contact us (e.g. customer support, need help, submit a request)
● Full name
● Email address
● Message
● If you contact us
through our social
media channels for
support, then we may
also potentially see your
username on the social
media platform from
which you reached out
to us
● To process and answer questions
● To provide support (e.g., to solve
problems, bugs or issues)
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
Legitimate interest (e.g. respond
to your request).
3
rd
party platforms such as Twitter/X,
Reddit, TikTok and Discord for
answering your questions and
providing support.
Cannot process
and answer
questions
Cannot provide
support (e.g.,
to solve
problems, bugs
or issues)
(c) When you subscribe to our distribution list(s) / newsletter(s) / blog(s) / social community(s)
● Full name
● Email address
● Usernames/Handles on
social communities (for
example, Reddit,
Discord)
● To add you to our mailing list
● To send you marketing communications
● To enable you to take part in our social
communities
Legitimate interest (e.g. to send
you marketing communications)
Consent (in some contexts)
3
rd
party platforms such as for the
following purposes:
In the case that the Platform sends
information via email, we may use 3
rd
party providers for sending the emails
and aggregating results.
Further, if we send out surveys (via
any channel, for example, a Google
Forms sent in our Reddit community),
then 3
rd
party services may have access
to the data you provide in the survey.
Cannot send
you marketing
communication
s
Cannot join our
social
communities
When we process your Input (As defined in our Terms of Use) to create Outputs (As defined in our Terms of Use) and/or you use the related features on the Platform
(a) When you create your Fig (bot) and/or multiplayer (multiple bot or multiple user) scenes
● Input (as defined in our
Terms of Use)
● Images(s)
● Descriptions and labeling
of Fig and/or multiplayer
scenes
● To provide you with the ability to create
Figs and/or multiplayer scenes
● To improve and develop our Platform
and new features and conduct research
● May also be used for marketing,
analytics, and statistic purposes
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
3
rd
party platforms such as for the
following purposes:
In case it is used in marketing,
analytics, and/or statistics (for
example, an ad featuring a Fig you
created), then some data may be
accessible to 3
rd
parties providing these
services (for example, Reddit Ads)
Cannot create
your character
Cannot provide
you with the
Outputs
(b) When you chat or interact with our services
● Input (as defined in our
Terms of Use)
● Account Information
(including usage of the
Identities feature)
● Other Information You
Provide
● To chat and interact with our Platform
● To improve and develop our Platform
and new features and conduct research
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
Cannot send
you messages
through the
Platform
Cannot provide
you with the
Outputs
When you engage with social features on our Platform (e.g., like, comment, follow/subscribe)
● Content of the interaction
(for example, content of
the message in a
comment), including
metadata (for example,
timestamp)
● To provide you with the ability to interact
with other users on the Platform
● To improve and develop our Platform and
new features and conduct research
Processing is necessary for the
performance of a contract to
which the data subject is party or
in order to take steps at the
request of the data subject prior to
entering into a contract.
Cannot use
social features
on the Platform
When you interact with us on our social media profiles (e.g., Reddit, Discord, Facebook, Instagram, Twitter/X, TikTok)
● Social Media Account
● Content of interaction
(text, images, etc.),
including metadata (for
example, timestamp)
● To process and answer questions
● To provide support
● To review our services
● To process your feedback
Legitimate interest
3
rd
party platforms such as for the
following purposes:
The 3
rd
party social media platforms
may have access to the data
communicated.
Cannot contact
with you on
social media
Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to
identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the
relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and
further use it for internal and external purposes, including, without limitation, to improve the services, to further the business and for research purposes. “Anonymous
Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services.
2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
2.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we
cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part
on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make
sure to take appropriate measures to protect this information.
2.2. Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please
note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with
legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or
(iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our
cookie policy
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3. HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal Data as follows:
3.1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
3.2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation,
federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
3.3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal
Data to such third party (whether actual or potential) in connection with the foregoing events;
3.4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer,
disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company
assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
3.5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional
additional services or functionality).
3.6. If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@figgs.ai.
4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
4.1 Internal transfers: Transfers to affiliates of Figgs will be covered by an internal processing agreement entered into by the affiliates of Figgs (an intra-group data processing
agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
4.2 External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain
contractual commitments from them to protect your Personal Data.
4.3 Transfer mechanisms: When Figgs engages transfers of personal information, it relies on Adequacy Decisions adopted by the European Commission based on Article 45
of the GDPR, Standard Contractual Clauses laid down by the European Commission, or any other approved transfer mechanism (such as the recipient's registration with
the EU-US Data Privacy Framework). Figgs continually monitors the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of
protection that is essentially equivalent to the level of protection guaranteed by the GDPR.
5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
5.1. Rights:
5.1.1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals
protected by the GDPR):
a. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge
an appropriate administrative fee where permitted by applicable law;
b. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
c. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are
required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
d. You have the right to object, to or to request restriction, of the processing;
e. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and
machine-readable format, and that you have the right to transmit that data to another controller;
f. You have the right to object to profiling;
g. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data,
in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the
lawfulness of processing based on consent before its withdrawal;
h. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer
agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
i. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of
alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us
before you contact your local supervisory authority and/or relevant institution.
5.2. You can exercise your rights by contacting us at privacy@figgs.ai. You may use an authorized agent to submit a request on your behalf if you provide the authorized
agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly
in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for
additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a
fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and
freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way
than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.3. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@figgs.ai. If you terminate your account, any association
between your account and Personal Data we store will no longer be accessible through your account, and Personal Data will not be deleted. However, given the
nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
5.4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@figgs.ai.
Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link
found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
6. USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about
children under the age of thirteen (13). If you are under the age of eighteen (18), do not provide any Personal Data to us without the involvement of a parent or a guardian.
For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal
Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at
privacy@figgs.ai
7. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that
are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be
aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third
Party Service.
8. ANALYTIC TOOLS
● We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic
information.
● We reserve the right to remove or add new analytic tools.
9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
9.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our
disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@clientname.com.
Please note that we are only required to respond to one request per customer each year.
9.2. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions
Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information
and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal
you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal
Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
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