THIS PRIVACY POLICY GOVERNS YOUR USE OF THE FOXTROT WEBSITE AND FOXTROT MOBILE APP (COLLECTIVELY, THE "APPLICATION")

Effective: August 1, 2024

WHAT INFORMATION DOES THE APPLICATION OBTAIN AND HOW IS IT USED?

USER PROVIDED INFORMATION

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

When you register with us and use the Application, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you choose to receive information from us via text messages; (d) information you provide us when you contact us for help; (e) credit card or other payment information for purchase and use of the Application, (f) your delivery address including street number, city and zip code and; (g) information you enter into our system when using the Application, such as contact information and project management information. We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.

AUTOMATICALLY COLLECTED INFORMATION

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your precise geographic location of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, information about the way you use the Application and other log data.

DO THIRD PARTIES SEE AND/OR HAVE ACCESS TO INFORMATION OBTAINED BY THE APPLICATION?

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement. We may disclose User Provided and Automatically Collected Information: (a) as required by law, such as to comply with a subpoena, or similar legal process; (b) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; (c) assist third parties, such as advertising technologies and publishers, to connect you to promotional advertising in their apps and websites or other third-party apps and websites that may be of particular interest to you on the basis of your use of our Application and other information they may collect about you, including for purposes of behavioral advertising and retargeting; (d) with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement; and (e) with our affiliates or otherwise within our corporate group; and with professional advisors, such as auditors, law firms, or accounting firms. We may disclose your User Provided and Automatically Collected Information if Further Point Acquisitions, LLC. is involved in a merger, acquisition, or sale of all or a portion of its assets. In such case you will be notified via email and/or via a prominent notice on our Web site of any change in ownership or updates to this privacy statement.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Application is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

You may control the way in which your devices permit the use of geo-location tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Application, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Application without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools Internet Option  Browsing History  Delete to view manual and automatic options.

To opt out of tracking by Google Analytics, click here

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

WHAT ARE MY OPT-OUT RIGHTS?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at support@foxtrotco.com.

DATA RETENTION POLICY, MANAGING YOUR INFORMATION

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. If you no longer want an account with us, you may delete your account inside the Application. For further questions, please contact us at support@foxtrotco.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

CHILDREN

We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at support@foxtrotco.com. We will delete such information from our files within a reasonable time.

SECURITY

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

CHANGES

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and at https://foxtrotco.com/privacy-policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

YOUR CONSENT

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing," means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards.

California Privacy Rights

Sharing for Direct Marketing Purposes

California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may from time to time elect to share certain “personal information” about you with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2019 will receive information about 2018 sharing activities).

To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per California resident each year.

California Consumer Privacy Act

Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act of 2018 (“CCPA”). We do not sell personal information collected about you.

Your Rights. Where applicable, if you are a California resident you may have the following rights under CCPA in relation to personal information we have collected about you; these rights are, subject to verification and any applicable exceptions:

· Right to Know/Access: the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:

o The specific pieces of personal information collected; The categories of personal information collected; The categories of sources from whom the personal information is collected;

o The purpose for collecting the personal information; and

o The categories of third parties with whom we have shared the personal information.

· Right to Delete: the right to request that we delete the personal information.

· Freedom from Discrimination: the right to be free from unlawful discrimination for exercising any of the rights above.

To make a request in relation to the above rights, please contact us using the information below under “Contact Us.” To fulfil your request, we will need to verify your identity, which may include asking you to log into your account. Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about California consumers:

Category of Personal Information	Examples	Collected?	Categories of Recipients to whom personal information is disclosed:
Identifiers	Name, e-mail address, address, IP address, zip code, gender	Yes	Data analytics vendors · IT service management vendors · Email distribution vendors · Marketing and digital advertising agencies · Market survey companies · Cloud service providers · Customer support and delivery service providers.
Personal information categories listed in the California Customer Records statute	Name; signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number; etc.	Yes	· Data analytics vendors · IT service management vendors · Email distribution vendors · Marketing and digital advertising agencies · Market survey companies · Cloud service providers
Protected classification characteristics under California or federal law	Gender	No	None
Commercial information	Products or services purchased	Yes	· Data analytics vendors · IT service management vendors · Email distribution vendors · Marketing and digital advertising agencies · Market survey companies · Cloud service providers
Internet or other similar network activity	Information on a consumer’s interaction with the Website or App.	Yes	· Data analytics vendors · IT service management vendors · Marketing and digital advertising agencies
Geolocation data	IP address data; precise location	Yes	· Data analytics vendors · IT service management vendors · Marketing and digital advertising agencies
Sensory data	Audio or video recordings.	No	· None
Professional or employment-related information	Title of profession; employer	Yes, should you submit an application for employment with us.	· IT service management vendors · Cloud service providers · Human resources service providers.
Inferences drawn from other personal information	Profile reflecting a person’s preferences	Yes	· Marketing and digital advertising agencies.

Purposes for Collection, Use, and Sharing.

We use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes:

· Auditing related to our interactions with you;

· Legal compliance;

· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;

· Debugging;

· Performing services (for us or our service provider);

· Internal operations;

· Activities to maintain and improve our services; and

· Other one-time or short-term uses.

CONTACT US

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at support@foxtrotco.com or contact us at 167 N Green St Suite 1100 Chicago IL 60611.