This Privacy Policy describes how Feeds ("we," "us," or "our") collects, uses, and discloses your information when you use our Feeds iOS application (the "App"). We are committed to protecting your privacy and handling your data in an open and transparent manner, in compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

1. Data Controller

Atini FZ-LLC is the data controller responsible for your personal data collected through the Feeds App.

2. Information We Collect

We collect various types of information in connection with the services we provide. This information helps us to operate, provide, improve, understand, customize, support, and market our services.

a. Information You Provide to Us

Account Information: When you create an account on our App, you are required to provide certain information. We use Frontegg, a proprietary identity and access management software solution (referred to as a "Platform" or "Service Provider"), to manage user authentication and authorization. When you use iOS or Google Single Sign-On (SSO) options, we receive anonymized tokens of your user identity. While Frontegg may create handles, you are not required to use your real name. The specific data collected by Frontegg to facilitate your account creation and management may include user profiles, audit logs, and authentication events.

b. Information We Collect Automatically

Interaction Data: We track all interactions you have with the feeds within our App. This includes, but is not limited to, what you like and dislike, content you schedule, reminders you set, and items you remove from your feeds. This data helps us understand your preferences and improve your experience.

Device and Usage Data: We collect certain information automatically when you access and use the App. This includes technical data such as your IP address, device information (e.g., device model, operating system version), and usage patterns. This data is collected via RudderStack, a "Service Provider" or "Data Processor" that collects, processes, and stores user data on our behalf to enable analytics, customer data platform functionalities, and related data services. For more details on the common fields collected, please refer to RudderStack's event specification documentation [1].

3. How We Use Your Information

We use the information we collect for various purposes, including:

•       To Provide and Maintain the App: To operate and deliver the services you request, including managing your account and personalizing your feed experience.

•       To Improve and Develop Our Services: To understand how you use the App, analyze trends, and develop new features and functionalities.

•       For Analytics and Performance: To monitor and analyze the usage and effectiveness of our App, and to diagnose and fix technical issues.

•       To Ensure Security: To protect the security and integrity of our App and prevent fraud.

•       To Comply with Legal Obligations: To meet our legal and regulatory requirements.

4. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

•       Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party (e.g., providing you with access to the App and its features).

•       Legitimate Interests: Processing is necessary for our legitimate interests, provided that these interests are not overridden by your fundamental rights and freedoms (e.g., improving our services, ensuring security).

•       Consent: In some cases, we may rely on your consent for specific processing activities, which will be clearly communicated to you.

5. Sharing Your Information

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

•       Service Providers/Data Processors: We engage third-party service providers to perform functions on our behalf, such as identity management (Frontegg), analytics (RudderStack), and infrastructure hosting (AWS, Databricks). These providers are contractually obligated to protect your data and only use it for the purposes for which it was disclosed.

•       Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

•       Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We do not sell your personal data to third parties.

6. International Data Transfers

Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. By using our App, you consent to such transfer.

We ensure that any international transfers of personal data are conducted in accordance with applicable data protection laws, including through the use of standard contractual clauses or other appropriate safeguards.

7. Your Data Protection Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

•       Right to Access: You have the right to request a copy of the personal data we hold about you.

•       Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.

•       Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data under certain circumstances.

•       Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.

•       Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.

•       Right to Object: You have the right to object to our processing of your personal data under certain circumstances.

•       Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request within one month.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. When determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Security of Your Information

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

support@feeds.ai

References

[1] RudderStack Common Fields. Available at: https://www.rudderstack.com/docs/event-spec/standard-events/common-fields/