Privacy Policy

This Privacy Policy was last updated on February 18, 2025.

Welcome to FinalLayer!

This Privacy Policy ("Policy") describes how Kasper d/b/a FinalLayer ("FinalLayer," "we," "us," or "our") collects, uses, shares, and protects information about users ("you" or "users") of the FinalLayer platform and all associated services (collectively, the "Service"). By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with this Policy in its entirety, you must immediately discontinue use of the Service.

1. Information We Collect

1.1 Information You Provide Us Directly

When you engage with our Service, you may choose to provide us with personal information. This primarily includes your email address, which is necessary for creating your account and completing our verification process through one-time passwords (OTP).

During your use of the Service, we collect and maintain records of your interactions with us. This encompasses your search queries, prompts, and any content you contribute to the Service, including textual, photographic, audio, video, or other multimedia materials (collectively referred to as "User Content").

We also gather information from your communications with us, whether through the Service itself or through other channels. These channels may include but not limited to email correspondence, in-person meetings, audio or video calls, particularly when you provide feedback, request support, suggest features, report bugs, or participate in user interviews.

Our processing of this information is conducted in accordance with our legitimate business interests in operating, maintaining, and enhancing the Service, as well as fulfilling our obligations to you under our Terms of Service. We utilize your information to provide customer support, implement product improvements, and address user feedback. We may contact you via email or other channels to deliver product updates, usage guidance, security alerts, and responses to your support inquiries or feature requests.

1.2 Information We Receive from Third-Party Applications

We receive and process information when you connect your LinkedIn profile to our Service, which may include your LinkedIn ID, name, organizational affiliation, access token, and post history. This data collection and processing are governed by LinkedIn's privacy policy and your LinkedIn privacy settings. By linking your LinkedIn account, you provide explicit consent for us to collect and process this information in accordance with this Privacy Policy. You maintain the right to disconnect your LinkedIn account at any time, after which we will cease receiving your LinkedIn information.

Additionally, when you interact with our social media presence on platforms such as Instagram, Facebook, TikTok, and LinkedIn, we may collect information you choose to share through these interactions, including your social media handles, name, location, profile photos, shared media, comments, and related activity. Such collection occurs in accordance with both this Privacy Policy and the respective social media platforms' privacy policies.

1.3 Information We Receive from Other Third Parties

We may collect information about you from various third-party sources, including public databases, social media platforms (such as Facebook, Instagram, LinkedIn, and Twitter), and third-party data providers. This information typically includes your professional details such as company affiliation, company size, job title, job level, and industry classification. We may share your email address or other identifying information with these sources to combine and enhance our understanding of your profile with the information you directly provide when using our Service.

The purpose of this data collection and combination is to deliver personalized experiences and targeted communications through various channels, including email, chatbots, phone conversations, and customized advertising. Our service providers may use cookies, pixels, tags, and similar technologies to combine data collected through our service with their existing contact information to improve offer relevancy.

For non-subscribers, we may obtain contact information from professional networks like LinkedIn or third-party data providers to share relevant product offerings that could benefit your professional role. We may also receive your information when other users refer you, share content with you, or when you interact with their shared content. Additionally, we collect data about your engagement with our advertisements from ad servers, ad networks, and social media platforms, including your pre-visit browsing activity, to evaluate advertising effectiveness and manage referral partner relationships.

1.4 Information We Collect Automatically

We and our approved third-party service providers automatically collect and process information about how you use our Service ("Usage Data"). We do this through technologies like cookies, pixels, tags, and other tracking tools (which we call "Tracking Technologies"). We handle all data collection in accordance with privacy laws and to improve our Service.

Usage Data includes information about your device (such as what type of device you're using, your operating system, device ID where applicable, and IP address). We also collect approximate location data to provide better service, when you allow us to do so. Additionally, we gather information about how you interact with our Service, including what browser you use, when you visit, what you click on, how you respond to our marketing emails, and what ads you see.

We look at this data in two ways: combined with other users' data (aggregated) and individually (unaggregated). When we look at combined data, it helps us understand overall patterns, like how many people visit our website during certain times. This information allows us to use advanced analytics and machine learning to make our Service better.

We use Usage Data to personalize your experience, improve the various agents that comprise the Service and your personal agent, analyze how our Service is used, and measure user engagement. We may also allow certain third-party service providers to use this data for similar purposes, but only under strict privacy and security requirements. Everything we do with your data is aimed at improving our Service while protecting your privacy.

1.5 Cookies and Similar Technologies

We and our authorized third-party partners utilize cookies and similar tracking technologies to process and store information about your interaction with the Service. Cookies are small text files containing unique alphanumeric identifiers that are placed on your browser. These technologies enable us to streamline the login process, optimize site navigation, maintain user preferences, analyze usage patterns, deliver interest-based advertising, measure performance metrics, and identify potential users of the Service.

Your browser typically accepts cookies by default; however, you maintain the right to modify your device's settings to control the deployment of tracking technologies. You may choose to block, delete, or limit cross-site tracking through your browser settings. Please be advised that restricting cookies may impair certain Service functionalities and features, potentially affecting your overall user experience. The Service may not operate optimally if cookie functionality is disabled.

You can opt out of Google analytics or Mixpanel analytics; opting out may impede our ability to optimize the Service for you.

1.6 Location Information

We collect and process your location information through various means, including:

(a) Direct provision, correction, or confirmation by you;

(b) Inference from your IP address;

Location data processing is conducted pursuant to our legitimate interests in providing location-specific features, localization, personalization, compliance with local laws and regulations, and improvement of service functionality.

2. How We Use Your Information

We process your personal information for the following purposes, based on our legitimate business interests, contractual obligations, your consent where required, and legal requirements:

Service Provision and Operation: We use your information to provide, maintain, and operate our Service, including processing account registrations, authenticating your identity, facilitating content management activities, and processing payments. This processing is necessary for the performance of our contract with you and to provide you with the requested services.

Analytics and Service Enhancement: We process your information to conduct data and usage analysis, identify areas for performance optimizations, index, label, and tag your User Content, develop and train our artificial intelligence agents and systems within the scope of our Terms of Service, and improve our Service functionality. This includes analyzing user behavior patterns, creating aggregated statistical data, and developing proprietary algorithms to enhance our Service and features. Tagging, labelling, and otherwise processing your User Content includes but not limited to analyzing, isolating, and understanding the text, speech patterns, speakers, objects, people, scenes, expressions, and other aspects of your text, audio, and video components.

Personalization and Communication: We utilize your information to personalize your experience, personalize AI agents, provide tailored content and recommendations, and communicate with you about Service-related matters. This includes sending administrative notifications, security alerts, and marketing communications (where you have consented and may opt out at any time). We process this information based on our legitimate interest in providing you with relevant content and maintaining necessary Service communications.

Safety, Security, and Compliance: We process your information to protect the security and integrity of our Service, detect and prevent fraud, enforce our Terms of Service, and 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.

Marketing and Advertisements: For advertising purposes, we may process your information to deliver targeted advertisements that may be of interest to you, measure their effectiveness, and improve our advertising strategies.

Customer Support: To ensure customer satisfaction and maintain service quality, we process your information to address feedback, respond to product and feature queries, provide support on user accounts and subscriptions, troubleshoot issues, and resolve errors.

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.

3. Sharing Your Information

3.1 Information Sharing Practices

We may share your information with the following categories of recipients:

(a) Service Providers and Business Partners

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

Payment processors for transaction processing
Analytics providers for Service analysis
Cloud storage providers for data hosting
Technology, including AI service providers
Marketing partners for promotional activities
Subsidiaries, contractors, and consultants

Such third parties are contractually bound to use the information only as necessary to provide their services to us and are prohibited from using it for other purposes.

3.2 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 other limited sets of users is available to the selected users. Any 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. However, copies of User Content or parts thereof may persist due to caching and archival, even after you revoke access previously shared media. You may also share User Content on other social media. You should review the privacy policies of the social media services that you share your User Content with to protect your private information.

3.3 Corporate Transactions

In connection with any merger, restructuring, sale of company assets, financing, or acquisition of all or a portion of our business by another company, 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. Aggregate user information, analytics, and other aggregate user information may also be shared from time to time in the context of financing, fundraising, and related due diligence. We may also share your data with professional advisors such as auditors, consultants, and legal and accounting experts. This is necessary for legitimate business purposes and is governed by applicable laws.

3.4 Legal Requirements and Protection

We may disclose your information if required to do so 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:

(a) Comply with legal obligations;

(b) Protect and defend our rights or property;

(d) Protect the personal safety of users or the public;

(e) Protect against legal liability.

4. Transfer, Storage, And Protection Of Data

We may transfer, store, and process your personal information in countries outside your jurisdiction of residence, including but not limited to the United States, where our primary servers and certain operational teams are located. Our support, engineering, and other teams who may analyze and maintain the data to operate and improve the Service, may work from countries outside of your jurisdiction of residence. 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.

You are responsible for keeping your account information confidential and for controlling access to communications from the Service at all times. The Service 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. The Service bears no responsibility for the functionality or security measures implemented by third parties. By using the Service, you acknowledge and accept these security limitations.

5. Your Choices About Your Information

You maintain control over your personal information through various mechanisms provided within the Service. You may access, update, or modify your account information at any time through your account settings. You may also control the communications you receive from us by adjusting your notification preferences. With respect to cookies and similar technologies, most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Service.

Regarding data analytics and machine learning, you may have options to control how we process your data for these purposes. 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, correct, delete, restrict processing of, and port your personal information, as well as the right to 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.

6. How Long We Keep Your Information

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include the nature of the information collected, the purpose for which it is used, technical and security considerations, and legal and regulatory requirements. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. If you request the deletion of your account, we will delete your information in accordance with applicable law and our data retention policies, though we may retain certain information as necessary for legitimate business purposes, including backups or as required by law.

7. Links to Third-Party Services

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. When you visit our Service through third-party links, any terms offered on third-party websites may not be applicable on our Service. Your interactions with third-party websites and services are governed by their respective privacy policies and terms.

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.

8. Country-specific Information

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 [email protected]; 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.

8.1 Considerations For Users In The United States

This section applies to FinalLayer users located in the United States. 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), and many others.

Personal Information Collection Information about FinalLayer’s personal information collection practices over the past twelve months is detailed in Section 1 "Information we collect." Our usage, sharing, and retention practices are described in Sections 2 "How we use your information," 3 "Sharing your information," and 6 "How long we keep your information."

8.1.1 State Privacy Rights

Under applicable state laws, residents may request access to their collected personal information, require deletion of their personal information, and correct any inaccuracies in their personal information. Residents may also opt out of the sale of their personal information and its sharing for cross-context behavioral advertising. Users have the right to appeal any denial of their rights requests.

8.1.2 Exercise of Rights

Users may submit privacy rights requests via [email protected]. 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. To opt out of personal information sales or sharing, including sharing with third-party advertisers, you may send your requests via [email protected].

9. Changes To This Policy

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.

10. How To Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or our privacy practices, please contact us at:

Kasper, Inc. d/b/a FinalLayer

Address:

2261 Market Street

STE 22429

San Francisco, CA 94114

Email: [email protected]

Phone: +1 (650) 300-3583

We will verify your identity before processing any rights requests to ensure the security of your personal information.

We maintain prior versions of this Policy in an archive for your review upon request. By continuing to access or use our Service after any revisions become effective, you agree to be bound by the updated Privacy Policy.