Privacy Policy

Introduction

Welcome to the privacy policy of Forage Group Inc. (“Forage”). Forage respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our digital platform or mobile application and tell you about your privacy rights and how the law protects you.

By visiting Forage’s website or making use of Forage’s digital platform or mobile application, you accept these practices. This document may be updated from time to time. When changes are made, the effective date at the top will be changed.

Chat Privacy

In general, messages are not stored, but messages which are flagged as suspicious may be stored indefinitely, and select messages may be read by a human being to improve quality control.

At the beginning of every chat, a record is made of the fact that a chat occurred between you and your chat partner. This record includes a timestamp, as well as IP address, ID cookie, and similar information for you and your chat partner. These records may be used for the purpose of tracking spammers, hackers, and others who pose harm to the site; and may also be used for law enforcement purposes; or analyzed in aggregate to produce statistical data (e.g., average number of chats started at different times of day).

Webcam images may be captured from Forage video chats, uploaded to Forage’s servers, and monitored for misbehavior as part of Forage’s moderation process. Captured images may also be stored and used to improve Forage’s moderation process.

Forage’s provides an unmoderated video chat mode. In this mode, the snapshotting and monitoring mentioned in the previous paragraph does not occur. 

Understand that strangers can potentially tell other people anything you tell them—by repeating what you said—and be careful what information you reveal to them. It is also possible for other users to take screenshots of video chats, or to use third-party software to record them. The IP addresses, ID cookies, and similar information related to the parties in the chat will be stored alongside the chatlog. 

The records Forage keeps may be shared with third parties for the purpose of law enforcement, to monitor and enforce compliance with Forage’s rules, or to improve Forage’s monitoring and enforcement processes.

Information made available to other chat users

In a Forage video chat, only the following information is made available to other Forage chat users:

  • Your first and last name, your profile picture, and your location.
  • A list of your social media accounts, if applicable.
  • The list of interests shared in common by you and the stranger, if applicable.
  • A notification that you and the stranger speak the same language (other than English), if that is the case.
  • A notification that you are using Forage’s mobile application, if that is the case.

Forage video chat requires a direct connection to be made between your computer and the other user’s computer. To do this, it is necessary to make your IP address available to the other user’s computer, although it is not shown to the other user by Forage’s interface. This is a necessary part of how any P2P video chat system functions.

Third-party software exists which acts as a virtual webcam. Forage may inform your chat partners if you are using this type of software.

Use of cookies

Forage uses cookies to save your preferences, including but not limited to the interests you add, as well as to store various non-personally-identifying technical information about your computer system (such as the capabilities it supports). Forage also assigns your computer a randomly-generated ID cookie.

Third party advertising vendors, including Google AdSense, use cookies to track information about the pages you visit, so that they can show you more appropriate ads. The cookie used by Google AdSense is called the DoubleClick DART cookie, and Google provides a way to opt out of being tracked by DART. [https://tools.google.com/dlpage/gaoptout] You may also opt out of the tracking cookies used by many (but not necessarily all) other third-party ad vendors.

Forage uses Google Analytics to track non-personally-identifying statistical information about site usage. Google provides a browser add-on to opt out of Google Analytics.

Parental control software

Parental control protections (such as computer hardware, software, or filtering services) are commercially available that may assist you in limiting access to material that is harmful to minors. If you are interested in learning more about these protections, information is available at http://kids.getnetwise.org/tools/ as well as a number of other Internet sites that provide information on this form of protection.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This privacy policy aims to give you information on how Forage collects and processes your personal data through your use of the website, digital platform and mobile application, including any data you may provide when you sign up or purchase a membership.

Forage is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Forage is the controller and responsible for your personal data (collectively referred to as “Forage,” “we,” “us,” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Forage Group Inc.

Postal address: 205 State Street, Apt. 15H, Brooklyn, NY 11201

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you reside within the EEA, you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See http://ec.europa.eu for those details. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.

Third-party links

Forage may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. In addition, Forage may include links to third-party plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check policies before you submit any personal data to these websites or use these services.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • “Identity Data” includes username or similar identifier and gender.
  • “Contact Data” includes your email addresses.
  • “Financial Data” includes payment card details.
  • “Transaction Data” includes details about payments from you and other details of products and services you have purchased from us.
  • “Technical Data” includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Forage, including your webcam and microphone.
  • “Device Data” includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.
  • “Content Data” includes information stored on your computer, mobile telephone, or handheld device, including login information, photos, videos, or other digital content streamed or broadcast on Forage (please remember that Content Data may reveal personal data about yourself as well), and access to camera and microphone.
  • “Profile Data” includes your username and password, purchases made by you, your interests, preferences, feedback, and survey responses.
  • “Usage Data” includes information about how you use our website, mobile application, products, and services, including traffic data and other communication data and the resources that you access.
  • “Google Login Data” includes your email address and password if you choose to link your Google account with us to facilitate account creation and logon process.
  • “Location Data” includes your current location disclosed by GPS technology and IP address, as well as information about proxies.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Forage feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you voluntarily provide it. Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact, Financial, and Marketing and Communications Data

  • purchase products or services;
  • create an account on Forage;
  • use Forage (even if you don’t signup);
  • download the mobile application;
  • make an in-App purchase;
  • share data via social media functions;
  • request marketing to be sent to you;
  • enter a competition, promotion, or survey;
  • report a problem; or
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with Forage, we will automatically collect Technical, Device, Content, and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical, Device, and Usage Data about you if you visit other websites employing our cookies.

• Location Data. We also use GPS technology and your IP address to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU; and
    • search information providers such as Google based outside the EU
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.
  • Identity, Contact, and Profile Data from Google based outside the EU if you choose to register and login using your Google account.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

  • Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
  • Promotional offers from us. We may use your Identity, Contact, Technical, Device, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
  • Third-party marketing. We will get your express opt-in consent before we share your personal data
  • Opting out. You can ask us or third parties to stop sending you marketing messages at any time by logging into Forage and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing messages sent to you, or by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result
  • Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
  • Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes stated above.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.

If you are located in the European Economic Area (EEA) or United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.

Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU–US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.

7. DATA SECURITY

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Forage, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

We will collect and store personal data on your mobile or handheld device using application data caches and browser web storage (including HTML5) and other technology.

Certain services include social networking, chat, comment, or timeline features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected, or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, 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, regulatory, tax, accounting, or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for seven years after they stop being paying customers for tax purposes.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. ACCESSING AND CORRECTING YOUR PERSONAL DATA

You can access, review, and change your personal data by logging in and visiting your account profile page.

You may also contact us to request access to, correct, or delete any personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

California, Canadian, EEA, and UK users may have additional personal information rights and choices. Please see below for more information.

10. DO NOT TRACK POLICY

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

11. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal data. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Privacy Notice for California Residents

California’s “Shine the Light” law (Civil Code Section 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. If you opt out from permitting your personal data to be shared, you may still receive selected offers directly from us in accordance with California law.

12. YOUR NEVADA PRIVACY RIGHTS

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request in writing at our address provided herein. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

13. YOUR CANADIAN PRIVACY RIGHTS

We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.

We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.

Residents of Canada are notified that the personal data they provide to us is stored in our databases outside of Canada and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.

You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.

You have the right to complain about our personal data handling practices.

14. YOUR EEA/UK LEGAL RIGHTS

If you reside in the EEA or UK, under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the link below to find out more about these rights: https://ico.org.uk/.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

If you wish to exercise any of the rights set out above, please contact us at the address provided herein: help@foragegroup.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15. GLOSSARY

“Consent” means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.