Oom by Fini - Privacy Policy

Our Policy

Welcome to the fini.world web site (the “Site”) of Finiliar Studios, Ltd. (“Company”, “We”, “Us” and/or “Our”). This Site is operated by Company and has been created to provide information about our website and mobile applications, including but not limited to “Oom,” our mobile application for conversations and chats (“Oom”) and, other related products and services (together with the Site, the “Services”) to our Service users (“You”, “Your”). This Privacy Policy sets forth Company’s policy with respect to information, including Personal Data and other information, that is collected from you in the course of your use of the Services. To the extent information is (a) associated with an identified or identifiable natural person and (b) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”.

Notice at Collection 

We may collect or process various categories of Personal Data. The section titled “Information Collection and Use” contains information on the categories of Personal Data collected and our disclosure practices. As an overview, we collect identifiers; commercial data; and audio, visual, or similar data.

We collect this information to deliver requested information to you, such as sending you newsletters or legal alerts; process your request for employment; perform services for which we have been engaged; maintain our business relationship with you; respond to your comments or requests for information; enforce any contracts that we enter into with you or the business you represent; or for other business or commercial purposes listed in the “Use of Data” section. We do not sell or share Personal Data. 

We do not collect, use, or disclose Sensitive Personal Data without your consent. You acknowledge and agree that you are providing consent for us to collect your Sensitive Personal Data, when you provide it, by creating of an account with us and by using Oom for a chatting and conversation experience which may involve your uploading of Sensitive Personal Data. 

We will retain the Personal Data listed above for as long as needed to fulfill the purpose for which it is collected and to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information Collection and Use

What Information We Obtain

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Information you give us

We collect Personal Data from you when you voluntarily provide such information during the course of using the Services or in response to when we ask for certain information, such as when you contact us with inquiries, register for access to the Services or use certain Services. You may not be able to use certain features if you choose not to submit information that is requested. This Personal Data and Sensitive Personal may include information such as:

• Contact information (e.g., name, mailing address, email address or phone number).
• Demographic, interests and household information (e.g., age, gender or education).
• Comments, photos, videos and other content or information you choose to submit, upload, input or publish on the Services or otherwise share with us, such as Conversations.
• Other information you may allow us to access through your device’s permissions settings, such as your contacts or address book.
• Transactional and activity information (e.g., requests, searches or orders).

In cases where you use our Services to submit or upload any content (e.g., text inputs/prompts, photographs, images, videos) for processing to get an output from the Service (e.g., a response from a chatbot), please be mindful of what your content may include. You should be cautious when submitting any content that may contain Personal Data or sensitive Personal Data).

Information automatically collected

The Services automatically log certain information about use or visits to the Services, such as the number and frequency of visitors, technical information about browsers and devices used to access the Services, and information about crashes or other technical issues. In addition, we and third parties may automatically collect certain information through automated means about your activities over time across the Services. 

The tools that collect this information vary depending on the Services and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits (“SDKs”). These technologies may be included in our web pages, mobile apps, emails, and other digital content. The tools may assign or collect unique cookie IDs or other identifiers associated with your browser or device. The tools may collect information while you are using our Services or while they are running in the background of your device.

The information automatically collected may include:

• Information about your computer, device, browser and operating system (e.g., type, model, or version).
• Internet protocol (IP) address, which may be used to derive your general geographic area (e.g., city and country).
• Device identifiers (e.g., mobile advertising IDs).
• Information about your interactions with the Services, including browsing activities and clickstream data that reflect the content you have accessed, clicked on, or viewed.
• Information about how you accessed the Services.

We use Amplitude, which is a web analytics service. They use cookies to help us analyze how users use the Services and enhance your experience when you use the Services. You can opt-out of certain features of this service by following the instructions in Amplitude’s Privacy Policy.  The Oom App will use Amplitude for analytics.  Any changes to this vendor will be published immediately.

Wherever Company collects Personal Data, we provide a link to this Privacy Policy. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Company and the authorized third parties referred to herein located in the United States.

Information we obtain from other sources

We receive information about you from other sources and it may be combined with other information about you. For example, we may obtain data from:

• Social media and other consumer platforms and similar services (“Social Media Platforms”). When you engage with our content or ads on Social Media Platforms, or interact with features on the Services that contain content or features provided by Social Media Platforms (e.g., login or sign in features or tools that allow you to share our content with others on Social Media Platforms), we may obtain information from Social Media Platforms, including your username, user ID, demographic information and other information, subject to the settings and privacy practices of the relevant Social Media Platform. We may obtain this information directly from the Social Media Platform or through plug-ins, integrations or applications. Please keep in mind that the operators of the Social Media Platforms may also gather information about your use of the Services and their features and tools.

Contacts

You may choose to provide us with your friends' contact information as stored on your phone. We ask your permission before getting access to your contacts, and you can still use the App without giving it access to your contacts (though you will have a harder time finding people you know who also use Oom).

If you grant us permission to access information about your contacts, which might include their name, profile picture, and phone number(s), we can notify you if any of your contacts are on Oom and when one of your contacts creates an Oom Account. We also notify your contacts on Oom that you have joined.

We do not store this contact information on our servers. When you open the App, we check to see if any of your contacts are on Oom by running the phone numbers in your contacts to match them with any registered Oom accounts. On our servers, we only store (i) contact information of people you have chats with on Oom and (ii) the phone number of people you have invited to join Oom.

We run an algorithm that uses this contact information to suggest which of your contacts you might like to connect with on Oom. We do not invite anyone in your contacts to join Oom without your permission.

Third Party Tracking; Do Not Track Signals

We do not use third party tracking technologies, but we may (and we may allow third parties to) use cookies or other technologies to collect information about your browsing activities over time and across different websites following your use of the Services. Our Service currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether a DNT signal is received. If we do so in the future, we will update and describe how we do so in this Privacy Policy. However, you may elect not to accept cookies by changing the designated settings on your web browser. Please note that some features of our Site may not function without essential cookies.

Non-Identifiable Data

When you interact with Company through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

How We Use Information We Obtain

To provide you with the Services. This includes:

• Processing your requests regarding the Services.
• Providing customer assistance or technical support.
• Customizing content, providing recommendations and enhancing the quality and your overall experience with the Services, including by retaining your user preferences or presenting content in the most effective manner for the browser or device you use to access the Services.
• Maintaining, operating, improving and developing the Services and related content, including developing new products and features based on users’ interactions with the Services and automatically updating the Services on your devices.
• Learning about users of the Services and analyzing how you and others interact with and respond to the Services, including by measuring and optimizing usage, reliability and performance, conducting market research, analyzing trends, and supporting our operations (e.g., for accounting, auditing, financial, legal or other purposes).

To communicate with you. This includes:

• Sending you informational messages about the Services (e.g., to confirm your activity or notify you of changes to a Service).
• Delivering marketing or promotional communications.
• Responding to your questions or addressing your requests.

For advertising and marketing purposes. This includes:

• Developing, managing and conducting advertising and marketing campaigns, promotions and offers, including about our products and services and other initiatives.
• Analyzing and measuring the performance, effectiveness and reach of our advertising and marketing efforts.

To protect our rights or the rights of others. This includes:

• Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Services, intellectual property infringement or other violations of law, this Privacy Policy, our Terms of Use or other Company policies and Agreements. 
• Performing audits, assessments and testing or troubleshooting activities.
• Backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Services.
• Complying with and enforcing applicable industry and legal requirements (including legal process such as court orders, warrants or subpoenas) and fulfilling contractual obligations.

Aggregated personal data

In an ongoing effort to better understand and serve the users of the Services, Company often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, to other third parties for other lawful purposes, or to the public for general advertising purposes.  

How We Share Information

Company is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

• Service Providers. In connection with the operation and provision of the Services, we engage various third parties to provide services or handle transactions on our behalf, such as payment card processing, cloud computing and analytics. These service providers use the information we provide to them as necessary or appropriate for the performance of their services.
  • SHOPIFY
    • Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
    • Payment: If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).
• Social Media Platforms. If you interact with social media widgets, share content using social media share buttons, or access features of the Services that contain content or features provided by Social Media Platforms, the relevant Social Media Platforms may collect information. We encourage you to review the privacy policies of the Social Media Platforms that you engage with as we are not responsible for their privacy practices.
• Other Parties When Required by Law or As Necessary to Protect Our Rights. We may share your information as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Services or other individuals and entities, or to comply with or enforce applicable industry standards, law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.
• Corporate Transactions. We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.
• With Your Consent or Otherwise at Your Direction. In addition, we may share your information with third parties when you consent to or request such sharing.

Your Choices

Direct Marketing Opt-Outs

• Email marketing. You may opt out of receiving marketing or promotional emails from us by clicking on the “unsubscribe” link contained in such emails. Depending on the Service you use, you also may be able to opt out of marketing or promotional emails by logging into your account and managing your email preferences. Please keep in mind that if you opt out of receiving marketing or promotional emails, we may still send you transactional emails or other communications relating to your use of the Services (e.g., to confirm your activity, to inform you of changes to a Service or in response to your password recovery request).

Website (Browser) Opt-Out

• Disabling Cookies. Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies.
  • If you choose to disable the use of cookies in your web browser, some features of the Services may become difficult to use or unavailable.
• Opt-out Cookies. You can follow the instructions provided by the Digital Advertising Alliance (“DAA”) here and/or the Network Advertising Initiative (“NAI”) here to place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser.

If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt- out choices for that specific browser.

• The opt-out mechanisms offered by the DAA and NAI are provided by third parties. Company does not control or operate these mechanisms, or the choices provided through these mechanisms.

Mobile App Opt-Out

• Device Settings. To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “Limit Ad Tracking ” for iOS or “Opt-out of interest-based ads” for Android.
• AppChoices Application. You can download the “AppChoices” application provided by the DAA from your app store. AppChoices offers a mechanism to limit the collection of app data used for interest-based ads by participating companies. See here for more.
• Please keep in mind that as the mobile environment continues to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that device manufacturers, technology companies and industry associations make available to you.

Do Not Track

Company does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

Additional Choices

• User account and information. If you have created an account on a Service, you may be able to review some of your information for that account by logging in and updating your information or user preferences. You may also submit a request to delete your account and certain Personal Data we have collected about you in connection therewith by sending your request to help@finiliar.com or the physical address provided in the Contact Us section of this policy. Your request to delete must provide sufficient information for us to specifically identify the information you are requesting to delete. Notwithstanding the foregoing, Company reserves the right to retain certain information i) for as long as necessary to provide the Services, ii) to comply with applicable law or regulation, iii) to prevent fraud, iv) to resolve disputes, and, v) to enforce any agreement with you and take any other actions permitted by law.
• Device Settings. For relevant Services, you may be able to review and adjust your preferences by updating the settings on your device.
• Push Notifications. If a Service enables push notifications on your device, you may review and update your push notification preferences by adjusting the settings on your device. For example, you can select the relevant app from “Notifications” (for iOS devices) or “App notifications” (for Android devices) and turn off alerts accordingly.

Security

Company takes reasonable and appropriate steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. We cannot guarantee its absolute security. Please keep this in mind when disclosing any Personal Data to Company via the Internet.

Non-U.S. Visitors and Users

We operate the Services from the United States. Any information we obtain about you in connection with your use of the Services may be processed and stored in the United States or other countries.

Children

Company does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. 

Special requirements for children in the EEA and the California Consumer Privacy Act, as amended. Due to requirements in the EEA and the state of California if you are an EEA or California resident, then you must be at least 16 years old to use our Services. To the extent prohibited by applicable law, we do not allow use by the EEA residents younger than 16 years old. If you are aware of anyone in the EEA younger than 16 using our Services, or if you have reason to believe that a child under the age of 13 has provided Personal Data to Company through the Services, please contact us at help@finiliar.com, and we will endeavor to delete that information from our databases.

Links to Other Properties or Services

This Privacy Policy applies only to the Services. The Services may contain links to other web sites or properties not operated or controlled by Company (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Company endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to this Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy will be governed by the terms of such revised Privacy Policy.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Company other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Company through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Other Terms and Conditions

Your access to and use of a Service is subject to the Terms of Service at https://www.fini.world/terms-of-use or any other agreement governing such Service.

Contact Us

If you have any questions about this Privacy Policy or your State Privacy Law rights, please contact us by email at help@finiliar.com. You may also contact us via USPS at Finiliar Studios, Ltd, 2810 North Church Street, 2810, PMB 66777, Wilmington, DE, 19802, Attn: Privacy.

Additional Information for California, Virginia, Connecticut, Colorado, Utah, Iowa, Indiana, Tennessee, Oregon, Montana, Texas, and Delaware 

This section applies only to residents of California, Virginia, Connecticut, Colorado, Utah, Iowa, Indiana, Tennessee, Oregon, Montana, Texas, and Delaware 

Categories of Personal Information We Collect

The California Consumer Privacy Act of 2018, as amended from time to time, and similar laws in other states (“State Privacy Laws”) may require specific disclosures for each category of personal information that we collect. The table below summarizes our general data handling practices which are more fully described in this Privacy Policy.

Your State Privacy Law Rights

Residents of the listed States may have the following rights:

• Right to know and access your personal information. Under applicable State Privacy Laws, you may have the right to:
  • Know the categories of personal information we collect and the categories of sources from which we got the information;
  • Know the business or commercial purposes for which we collect and share personal information;
  • Know the categories of third parties and other entities with whom we share personal information; and
  • Access the specific pieces of personal information we have collected about you.
• Right to deletion. In some circumstances, you may ask us to delete your personal information.
• Right to correct. If you believe your personal information is not correct, you may provide personal information to replace the erroneous data.
• Right to opt out of sales. We do not currently share your personal information with third parties in ways that may constitute a “sale” under State Privacy Laws. In the event that we do so in the future, we will update this Privacy Policy and you may then request that we not “sell” your personal information on a going forward basis. If you reengage with us after opting out of the “sale” of your personal information, such as by purchasing or subscribing to a product or service or signing up for communications your personal information will be collected and used in accordance with this Privacy Policy. Individuals in California may request their information not be shared with any third party.
• To exercise any of the above, please submit your request to help@finiliar.com and include your name, email address, phone number, and postal address.
• Right to be free from discrimination. You may exercise any of the above rights without fear of being discriminated against. We are permitted to provide a different price or rate to you if the difference is directly related to the value provided to you by your data.

Any request must provide sufficient information for us to specifically identify the information you are requesting to address.

For any of the above-mentioned rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide including information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.

We will use the information you provide to make your State Privacy Law rights requests to verify your identity, identify the personal information we may hold about you and act upon your request. We strongly recommend that you submit the email and postal address that you used when you created accounts, subscriptions or signed up for communications. After you submit a State Privacy Law rights requests, you may be required to verify access to the information you submitted for us to proceed with your rights requests. Please check your spam or junk folder in case you can't see verification emails in your inbox. If you are a resident of the States listed above and have any questions regarding your rights under this Privacy Policy, please contact us at help@finiliar.com.

Minors

We do not knowingly collect or disclose personal information of minors under the age of 16, without affirmative authorization.

Additional Information for EEA and UK Residents

The following section applies only to individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”).

Legal bases for using your information

We process personal information for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases:

• To perform our contractual obligations to you. We and our service providers process your information to perform our contractual obligations to you when we use your information to provide you with the Services and related content, products or services and to communicate with you. For example, when you purchase a product, service or subscription from us, we process your payment and contact information as necessary to confirm the purchase and we process your contact information and other details to provide you with support services you request. We also send you informational communications on this basis, including to confirm activity or to notify you of a change to a Service. Failure to provide requested information could prevent or delay the fulfilment of our contractual obligations.
• To pursue our legitimate interests. We process your information to meet our legitimate interests when we use your information to provide you with the Services and related content, products or services, to communicate with you and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Services and related content, products or services, and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries, service providers and business partners (including for our advertising and marketing purposes) and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
• To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. For example, we may be required to collect certain information from you when processing your purchase payments for tax or financial reporting reasons.
• With your consent. We obtain your consent to process your information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the “Contact Us” section above. You will not be able to use the Services, however, if you withdraw your consent to our processing of your information.

Additional rights

In addition to other rights you may have under this Privacy Policy, as an individual located in the EEA or UK you have the right to:

• request copies of your Personal Data (we may charge you a small fee for this service);
• where Personal Data is inaccurate or incomplete, ask for Personal Data to be rectified or completed;
• request the transfer of your Personal Data to another party;
• ask that Personal Data be erased;
• make a complaint to an applicable data protection authority about the manner in which we process your Personal Data; and
• object to us processing your Personal Data by asking for the processing of that Personal Data to be restricted or stopped, under certain conditions.

Any request must provide sufficient information for us to specifically identify the information you are requesting us to address.

If you would like to discuss or exercise such rights, please contact us at help@finiliar.com. We will contact you if we need additional information from you in order to honor your requests.

Storing your information

We may keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we may retain your personal information for a period of time that enables us to:

• Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Services.
• Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
• Defend, establish, exercise or bring any existing or potential legal claims.
• Carry out fraud detection and prevention.
• Deal with any complaints regarding the Services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

International transfers of information we collect

Information collected through the Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. If we transfer personal data from the EEA, UK and Switzerland we put in place safeguards. In particular, such safeguards include European Commission-approved standard contractual clauses. For more information on these safeguards, please contact us at the details provided in the “Contact Us” section above.

Changes to the Privacy Policy

Where changes to this Privacy Policy have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will post advanced notice so that you have the opportunity to exercise your rights (e.g., to object to the processing).

Privacy Officer and Complaints

We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about privacy. We can be contacted at help@finiliar.com. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.