Privacy Policy

3.1 Service Provision and Operation

• Process account registrations and authenticate your identity
• Facilitate content management activities
• Process payments
• Provide the requested Service features

This processing is necessary to perform our contract with you.

3.2 Analytics and Service Enhancement

• Conduct data and usage analysis
• Identify performance optimization opportunities
• Index, label, and tag your User Content
• Develop and train artificial intelligence agents and systems within the scope of our Terms of Service
• Improve Service functionality

This includes analyzing user behavior patterns, creating aggregated statistical data, and developing proprietary algorithms to enhance Service features. Processing your User Content includes analyzing text, speech patterns, speakers, objects, people, scenes, expressions, and other aspects of your text, audio, and video components.

3.3 Personalization and Communication

• Personalize your experience and AI agents
• Provide tailored content and recommendations
• Communicate with you about Service-related matters
• Send administrative notifications and security alerts

We process this information based on our legitimate interest in providing you with relevant content and maintaining necessary Service communications.

3.4 Safety, Security, and Compliance

• Protect the security and integrity of our Service
• Detect and prevent fraud
• Enforce our Terms of Service
• Comply with applicable laws and regulations

This processing is necessary to fulfill our legal obligations and protect our legitimate business interests and the interests of our users.

3.5 Customer Support

• Address feedback and respond to queries
• Provide support on user accounts and subscriptions
• Troubleshoot issues and resolve errors
• Maintain service quality

We may also process your information for other purposes with your explicit consent, which you may withdraw at any time. All data processing activities are conducted in accordance with applicable data protection laws and our commitment to data minimization and purpose limitation principles.

4.1 Service Providers

We share information with third-party service providers who assist in operating, maintaining, and improving the Service, including:

• Payment processors – For transaction processing
• Cloud storage providers – For secure data hosting
• Technology and AI service providers – For core Service functionality
• Analytics providers – For Service analysis and improvement
• Security providers – For fraud prevention and security monitoring

These service providers are contractually bound to:

• Use your information only as necessary to provide their services to us
• Implement appropriate security measures
• Not use your information for their own purposes
• Comply with applicable data protection laws

Important: Google user data is shared only with service providers who are strictly necessary to provide the Service and who are bound by contractual obligations to protect your data and use it only for authorized purposes.

4.2 User Content Sharing

You may choose to share User Content through the Service, which may include personal information:

• Information you share with your team or selected users is available to those users
• Information you share through public features of the Service will be available to other users and the public
• The Service may provide capabilities to revoke access to other users

Please note: Copies of User Content may persist due to caching and archival, even after you revoke access. If you share User Content on social media, review those platforms' privacy policies to protect your information.

4.3 Corporate Transactions

In connection with any merger, restructuring, sale of company assets, financing, or acquisition of all or a portion of our business, user information may be shared or transferred. You will be notified via email and/or prominent notice on the Service of any change in ownership or uses of your personal information.

We may share aggregated user analytics and statistics in the context of financing, fundraising, and due diligence. We may also share your data with professional advisors such as auditors, consultants, and legal and accounting experts as necessary for legitimate business purposes.

4.4 Legal Requirements and Protection

We may disclose your information if required by law or in response to valid requests from public authorities (e.g., court orders, subpoenas). We may also disclose your information where we reasonably believe such disclosure is necessary to:

• Comply with legal obligations
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing
• Protect the personal safety of users or the public
• Protect against legal liability

We may transfer, store, and process your personal information in countries outside your jurisdiction of residence, including the United States, where our primary servers and operational teams are located. Our support, engineering, and other teams who analyze and maintain data to operate and improve the Service may work from countries outside your jurisdiction.

These transfers may involve countries with different data protection standards than your country of residence. These international transfers are necessary for the provision of our Services and the fulfillment of our contractual obligations to you.

We ensure that any international transfer of personal information complies with applicable data protection laws. When you use our Services and accept this Privacy Policy, you expressly consent to these international transfers, including the transfer of your personal information to countries where we maintain databases, have affiliate operations, or engage third-party service providers.

For transfers to our service providers and other third parties, we implement appropriate safeguards through contractual requirements and ensure compliance with relevant data protection regulations.

Your Responsibilities

You are responsible for:

• Keeping your account information confidential
• Controlling access to communications from the Service at all times

Security Limitations

While we implement industry-standard security measures, we cannot guarantee or warrant the security of information you transmit or ensure that information on the Service will not be accessed, disclosed, altered, or destroyed by unauthorized parties. Changes to third-party services and social networks that you integrate with the Service may affect your privacy settings. We bear no responsibility for the functionality or security measures implemented by third parties. By using the Service, you acknowledge and accept these security limitations.

6.1 Account Information

• Access, update, or modify your account information at any time through your account settings
• Control the communications you receive from us by adjusting your notification preferences

6.2 Cookies and Tracking Technologies

• Most web browsers are set to accept cookies by default
• You can choose to set your browser to remove or reject browser cookies
• Removing or rejecting cookies may affect the availability and functionality of the Service

6.3 Google Account Access

• Revoke FinalLayer's access to your Google account at any time through your Google Account permissions page at https://myaccount.google.com/permissions
• When you revoke access, we immediately stop accessing your Google data

6.4 Data Rights

Where we rely on consent for certain processing activities, you have the right to withdraw such consent at any time. You may also have specific rights under applicable data protection laws, including the right to:

• Access your personal information
• Correct your personal information
• Delete your personal information
• Restrict processing of your personal information
• Port your personal information
• Object to certain processing activities

To exercise these rights, please contact us using the information provided in the "How to Contact Us" section of this Policy.

Retention Criteria:

• The nature of the information collected
• The purpose for which it is used
• Technical and security considerations
• Legal and regulatory requirements

Deletion:

When we no longer need to use your information and there is no need to keep it to comply with legal or regulatory obligations, we will either:

• Remove it from our systems, or
• Anonymize it so it can no longer be associated with you

Account Deletion:

If you request the deletion of your account, we will delete your information in accordance with applicable law and our data retention policies. We may retain certain information as necessary for legitimate business purposes, including backups or as required by law.

Google User Data Retention:

• Email address and basic profile information: Deleted within 30 days of account deletion
• OAuth tokens: Invalidated immediately upon account disconnection or deletion

The Service may contain links to and from third-party websites, apps, and services. We do not control, endorse, or assume responsibility for any third-party websites, services, or content. When you leave our Service through such links, our Privacy Policy no longer applies.

If you grant third-party services (such as social media platforms) access to your User Content through the Service, you do so at your own risk. We cannot control how these third parties collect, use, or handle your information once you authorize such access.

This Privacy Policy applies solely to information collected through the Service and does not cover information collected through other channels or offline methods.

Our Service is available in Argentina, Brazil, Canada, Colombia, Egypt, India, Indonesia, Israel, Mexico, Nepal, Nigeria, Philippines, South Africa, Sri Lanka, Thailand, Tunisia, United States, and Vietnam as of this version. If you are not in these countries, please send an email to support@finallayer.com; we'll add you to the waiting list and inform you when the service is ready in your country. We are working to enable the service worldwide within the next few quarters.

9.1 Considerations for Users in the United States

This section applies to FinalLayer users located in the United States.

State Privacy Rights

Users in certain U.S. states have specific privacy rights under state laws, including the California Consumer Privacy Act (as amended by the California Privacy Rights Act). Information about FinalLayer's personal information collection practices over the past twelve months is detailed in Section 2 "Information We Collect." Our usage, sharing, and retention practices are described in Sections 3 "How We Use Your Information," 4 "Sharing Your Information," and 7 "How Long We Keep Your Information."

Your Rights

Under applicable state laws, residents may:

• Request access to their collected personal information
• Require deletion of their personal information
• Correct any inaccuracies in their personal information
• Appeal any denial of their rights requests

Exercise of Rights

Users may submit privacy rights requests via support@finallayer.com. We will verify requests using the email address associated with the user's FinalLayer account and may require proof of state residency. Appeals of denied requests may be submitted to the same email address and will be processed based on applicable privacy laws and regulations.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Policy, we will notify you by email (sent to the email address specified in your account) or by means of a prominent notice on our Service prior to the changes becoming effective.

Your continued use of the Service after any modification to this Policy will constitute your acceptance of such modifications. We encourage you to periodically review this Policy to stay informed about how we collect, use, and protect your information.