Privacy Policy

Last Revised: 03/08/2024

FairPlay™ AI (“we”) recognize the importance of privacy.  In this privacy policy (the “Privacy Policy”), we describe how we collect, use, and disclose information that we obtain from visitors to our websites www.fairplay.ai, www.fairplay.ai and www.fairness-as-a-service.com (the “Sites”) as a business.

THIS PRIVACY POLICY DOES NOT APPLY TO CONSUMER PERSONAL INFORMATION THAT WE RECEIVE FROM OUR CORPORATE CUSTOMERS IN CONNECTION WITH OUR FAIR LENDING ANALYTICS SERVICES.  WE PROCESS THAT DATA IN OUR CAPACITY AS A SERVICE PROVIDER PURSUANT TO SEPARATE CONTRACTUAL TERMS WITH OUR CORPORATE CUSTOMERS.

By visiting the Sites, you agree that any information that we collect from or about you through the Sites, including Personal Information, anonymous information, and aggregate information (collectively, “Information”), will be handled as described in this Privacy Policy.  We define “Personal Information” as personally identifiable information about an individual person, such as a name, address, email address, phone number, or other identifier that permits contacting of a specific individual, or such other definition that applies under applicable privacy laws.

Your use of the Sites and any dispute over privacy, is subject to this Privacy Policy which is incorporated via reference into our Terms of Use (the “Terms”), including the applicable limitations on damages and the resolution of disputes set forth therein.  Capitalized terms not defined herein are as defined in the Terms.

• Information we collect.  We collect Information directly from you, from third parties, or automatically through your use of the Sites.  We may combine Information collected through the Sites with Information provided through other sources (e.g., trade shows, conferences, market intelligence platforms, publications, and academic resources).

• Information we Collect Directly from you.  We will collect any Information that you choose to provide to us through the Sites, such as your name, email address, account credentials, the contents of any message submitted through the “Contact Us” feature of the Sites, and the contents of your resume and job application if you apply for a job through the Sites.
• Information we Collect Automatically.  We automatically collect Information through your use of the Sites using cookies and other technologies, like most other web-based services.  This Information may include, without limitation, information about your operating system, settings and system configurations, IP address, device model, device ID and other unique device identifiers, the webpages you access within our Sites, the website that led you to the Sites, the website to which you go after leaving the Sites, links you click within the Sites, the dates and times you access the Sites, event information (e.g., system crashes), and web log data.
• Aggregated Data. We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”).  Aggregated Data may be derived from your Personal Information but is not Personal Information.  For example, we may aggregate Site usage data to calculate the percentage of users accessing a specific Site feature.  However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

2. How we Use your Information.  We use Information, including Personal Information, for the following purposes:

• Cookies. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout
• Providing the Site.  To provide and enhance the Sites and for other customer service purposes and to ensure that our content associated with the Sites is most effective for you and your device.
• Communicating with you or Others.  To communicate with you, including via email, about the Sites; to respond to your inquiries; to provide you with news and newsletters, special offers, and promotions; to contact you about products or information we think may interest you; and for other marketing, advertising, and promotional purposes.
• Marketing and Advertising.  To provide you with news and newsletters, special offers, and promotions, including via email; to contact you about products or information we think may interest you; and for other marketing, advertising, and promotional purposes; in each case from which you can unsubscribe at any time.  We will procure your consent prior to initiating any marketing or advertising messages to the extent consent is required under applicable privacy and data protection laws.
• Analyzing Use of the Site.  To better understand how users access and use the Sites, both on an aggregated and individualized basis; to respond to user desires and preferences; for other research, analytical, and statistical purposes; and to monitor the security or your use of the Sites.
• To Protect Rights and Interests.  To protect our rights and interests as well as the rights and interests of our users and any other person – as well as to enforce this Privacy Policy and the Terms.
• Complying with the Law. To comply with applicable legal obligations, including law enforcement or governmental requests for information.

3. How we Disclose your Information.  We may disclose Information, including Personal Information, with the following entities:

• Affiliates.  We may disclose Information to any current or future affiliates, parent companies, or subsidiaries.
• Service Providers.  We may disclose Information to vendors, service providers, agents, contractors, or others who perform functions on our behalf.  These service providers have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may also disclosure Information, including Personal Information, for the following purposes:

• Business Transfers.  We may disclose Information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer.  If another company acquires our business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Policy.
• Legal Compliance. We may disclose Information in order to comply with the law, regulation, a judicial proceeding, subpoena, court order, or other legal process, including law enforcement or governmental requests for information; provided, however, that to the extent we are legally permitted to do so and it is practicable to do so, we will seek to notify you prior to sharing your Personal Information pursuant to this section.
• Protecting Rights and Interests. We may disclose Information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, or other purposes.

4. Cookies and other Tracking Mechanisms.  We and our service providers use cookies and other tracking mechanisms to track your use of the Sites.

• Cookies. We or our service providers may use cookies to track visitor activity on the Sites such as the pages visited and time spent on the Sites.  A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes.  Most browsers allow users to refuse cookies.  The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  Visitors to the Sites who disable cookies may not be able to browse certain areas of the Sites.
• Clear GIFs, pixel tags and other technologies.  Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages.  We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with the Sites to track the activities of visitors to the Sites, help us manage content, and compile statistics about usage of the Sites.  We or our service providers may also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
• Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit.  Flash LSOs are different from browser cookies because of the amount and type of data stored.  Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser.  For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions.  To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
• Do Not Track.  The Sites do not respond to Do Not Track signals sent by your browser at this time.  You may disable certain tracking as discussed in this section (e.g., by disabling cookies).

1. Third Party Analytics and Advertising.  We may use service providers to help us evaluate use of the Sites.  We or our service providers use automated devices and applications to evaluate use of the Sites and to help us improve the Sites, their performance, and user experiences.  These entities may use cookies and other tracking technologies, such as web beacons or Flash LSO, to perform their services.  To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

5. Security.  We have taken steps to help protect the Personal Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.  We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
6. Data Retention.  We retain your Personal Information for as long as necessary to achieve the purposes for which they were collected, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
7. Your Choices.  We may send periodic promotional emails to you.  You may opt out of such communications by following the opt-out instructions contained in the email.  Please note that it may take up to ten (10) business days for us to process opt-out requests.  If you opt out of receiving promotional emails, we may still send you emails about products or services that you have requested or received from us.
8. Miscellaneous.  Our Sites are not targeted to children under thirteen (13) years of age.  If we discover that a child under thirteen (13) has provided us with Personal Information, we will promptly delete such Personal Information from our systems.  The Sites are controlled and operated from facilities in the United States and we make no representations that the Sites are appropriate or available for use in other locations.  However, if you use the Sites, you understand and acknowledge that your Personal Information will be transferred to, processed and stored in, the United States, which may have less comprehensive privacy laws that the country in which you are based.  California residents may request a list of certain third parties to which we have disclosed your Personal Information for their own direct marketing purposes.  You may make one request per calendar year.  In your request, please attest to the fact that you are a California resident and provide a current California address for your response.  You may request this information in writing by contacting us.  Please allow up to thirty (30) days for a response.  This Privacy Policy is current as of the effective date set forth above.  We may change this Privacy Policy from time to time by posting an updated version to the Sites, so please be sure to check back periodically.  If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on the Sites.  If you have questions about the privacy aspects of the Sites or you wish to exercise any legally-granted rights with regard to your Personal Information, please contact us at insert email address.