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PRIVACY

Privacy is important to us, so we strive to be as transparent as possible. We do not and will never sell your data, and we do our best to purge your personal information from our online systems as soon as possible.

DATA RETENTION

When making a purchase on this website, we store your personal data – your name, addresses, phone number, and email – for 60 days after your order ships. After 60 days, this data is automatically purged from our online systems.

Your order number remains in our system, but your name, phone number, and addresses are deleted and no longer associated with your order number.

Your email is also no longer associated with your order number, but preserved in our self-hosted email marketing tool to update you with important company announcements, including security notifications and firmware updates. You can unsubscribe from our emails at any time.

Please note that, as part of our normal business, we are required to share your personal data with the following partners:

  • Credit Card Processor (if you pay with a credit card)
  • Shipping Label Generator (we frequently purge this data)
  • Shipping Company, usually UPS or USPS (they have their own separate policies for purging data, but it’s usually gone after 6 months)
  • Google Workspace (any time you email us, such as corresponding with our customer support)
  • SMTP Email Provider (for sending transactional and marketing emails; they log emails for 2 days)
  • Web Host (which hosts this website and other Foundation services)

We always recommend purchasing from us pseudonymously using a remailer service, work address, or PO Box. Learn more about buying Passport in the most private way possible on our blog.

 


PRIVACY POLICY

Effective date: March 11, 2024.

This “Privacy Policy” describes the privacy practices of Foundation Devices, Inc. (collectively, “Foundation Devices”, “we”, “us”, or “our”) in connection with the https://foundation.xyz website (the “Site”), our mobile companion app, Envoy (“Envoy”, and together with the Site, the “FD Platforms”) and the informational services made available through the FD Platforms, including our Concierge Onboarding service (the FD Platforms and such services collectively, the “Services”), and the rights and choices available to individuals with respect to their information.

Foundation Devices may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

1. PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you provide to us through the Services or otherwise includes:

  • Information necessary to make a purchase, such as your first and last name, email and mailing addresses, phone number, credit card information, products purchased and, if purchasing using Bitcoin, the information collected in connection with such payment.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic Information, such as your city, state, country of residence, and postal code.
  • Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us.
  • Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.
  • Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services, including but not limited to your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing our website, general location information such as city, state or geographic area; information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), and similar technologies.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We use your personal information to:

  • provide, operate and improve the Services, including to delivery any purchased products or services
  • provide information about our products and services
  • communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about events or contests in which you participate
  • provide support and maintenance for the Services
  • to respond to your requests, questions and feedback

For research and development. We analyze use of the Services to analyze and improve the Services and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications. We may send you Foundation Devices-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. The fundamental philosophy of our company and the decentralized movement we serve is grounded in protecting your data, privacy and anonymity in every way possible.  That being said, there may be extenuating circumstances in which we are required by law or governmental decree to comply with requests to share the very limited amount of your data, if any, we have in our system. That being the case, we may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as web hosting, email delivery, and credit card processing services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

4. YOUR CHOICES

In this section, we describe the rights and choices available to all users.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the applicable FD Platforms may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

5. OTHER SITES, MOBILE APPLICATIONS AND SERVICES

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

6. SECURITY PRACTICES

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

7. INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

8. CHILDREN

As a general rule, children are not allowed to use the Services, and we do not collect personal information from them. We define “children” as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

10. HOW TO CONTACT US

Please direct any questions or comments about this Policy or privacy practices to [email protected]. You may also write to us via postal mail at:

Foundation Devices, Inc.
Attn: Legal – Privacy
6 Liberty Square #6018, Boston, MA 02109