Introduction
 
Welcome to Afiniii LLC (“Afiniii,” “we,” “us,” and/or “our”) operates the website (https://www.afiniii.com) (the “Site”), our iOS and Android mobile application and related services (collectively, the “Services”) to our Service visitors (“you,” “your”). This Privacy Policy sets forth Afiniii’s policy concerning the collection of personal data (including as defined under privacy rights and consumer data protection laws in various states) (collectively, “Personal Data”) from visitors to the Site and Services. In addition, your access to and use of the Services is subject to the Terms of Service, which Afiniii may update occasionally.
 
Our Services are intended for individuals over the age of 16 in the United States only.
 
If you are under 16, you are not authorized to use the Services, with or without registering. If you are under 18, you may use the Services, with or without registering, only if you have the approval of your parent or guardian. If you are a parent or guardian of a user under 18 (or the age of majority in your state), you authorize and are responsible for all account activity taken by the minor user.

If you provide Personal Data to the Services, it may be transferred from your current location to the offices and servers of Afiniii and the authorized third parties referred to herein.
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Information We Collect 
 
When you interact with us through the Services, we collect Personal Data and other data from and about you to provide the Services.
 
Personal Data You Provide Through the Services 
 
When you use the Services, we collect Personal Data from you and voluntarily provide such information as when you sign up for an Afiniii account, create contact groups, send requests, and receive replies. This Personal Data may include:
 
-  Your given name, family name, email address, and mobile phone number if you create an Afiniii account. We use this information to provide you with the Services, communicate with you, and provide account security.
 
-  A device identifier associated with your mobile device. We use this information to monitor your account for fraudulent activity.
 
-  Your history of Afiniii use, including the contact names, phone numbers, and phone number types of the people to whom you send requests, each request's group name, subject, and request, view and reply status, sorting category for each request, and timestamps for each action.
 
-  Payment method, transaction timestamps, and credit and debit card charge amount if you use the Afiniii Wallet feature to compensate/tip Afiniii after use. Afiniii does not store any personal credit or debit card information. Please see Third-Party Personal Data Processing below for more information.
 
-  A record of your touchscreen interactions with the user interface for our Services (excluding data that you may input). We use this information to identify design problems with our user interface and to provide a better user experience.
 
-  For a small subset of users, we may collect additional categories of Personal Data that those users voluntarily provide us while using the Services. For example, a user may provide contact information such as an email address, mobile phone number, or mailing address while interacting with customer support. A user may provide a state of residence when submitting a privacy request.
 
-  In addition to these categories of Personal Data collected by Afiniii, Afiniii creates and assigns a unique user identifier (Afiniii UUID) to every Afiniii account at the time of creation.
 
Third-Party Personal Data Processing
 
For some functionality, Afiniii relies on third-party service providers to collect and process Personal Data from users directly, which may include using an application programming interface (API) on the mobile application.
 
-  We require you to provide your phone number and email for multi-factor authentication, which increases security while using the Services. Multi-factor authentication typically consists of a unique and temporary code sent to your phone via text message or email for additional authentication on the app. We use a third-party software API to facilitate multi-factor authentication functionality within Afiniii.
 
-  Users who add a credit or debit card to their Afiniii Wallet or utilize the Afiniii Wallet feature are prompted to input their name, credit card or debit card number, expiration date, CVC code, and zip code associated with their billing address. Our third-party partners, Apple and Google, collect this information, which has not been shared with Afiniii. Our third-party partners use the Personal Data collected to validate your credit or debit card and initiate charges you authorize. These providers may also share this Personal Data with their payment processing partners to enable the Afiniii Wallet functionality, activate and validate changes to your card account, and reconcile the actual purchase amount using Afiniii Wallet. Our third-party partners’ Privacy Policies are accessible here: Apple: Privacy Policy  //  Google: Privacy Policy  //  Users who wish to exercise their rights regarding our third-party partners should contact them directly.

Our Use of Your Personal Data and Other Data
 
Afiniii uses the Personal Data you provide in a manner consistent with this Privacy Policy. If you provide personal data for a certain reason, we may use it to explain why it was provided. For instance, if you contact us by email, we will use your personal data to answer your questions or resolve your problem. Also, if you provide Personal Data to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Afiniii and its agents and service providers may also use your personal data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, better understand our users, and improve the Services. Afiniii may use this information to contact you about services we believe will interest you. If we do so, each marketing communication we send will contain instructions permitting you to “opt out” of receiving future marketing communications. If you wish not to receive any future marketing communications or to have your name deleted from our mailing lists, please contact us as indicated below.
 
In addition, Afiniii researches its customer demographics, interests, and behavior based on the Personal Data and other data provided to us to better understand and serve the users of the Services. This research may be compiled and analyzed on an aggregate basis. Afiniii may also disclose aggregated user statistics to describe our services to current and prospective business partners and third parties for other lawful purposes.

Our Disclosure of Your Personal Data and Other Data 
 
Afiniii is not in the business of selling or sharing information we collect. We consider this information a vital part of our relationship with you. There are, however, certain circumstances in which we may provide your Personal Data to certain third parties without further notice to you, as set forth below:
 
Business Transfers. We might sell or buy services, businesses, or assets as we develop our business. Personal Data may be part of the transferred assets in a research sale, corporate sale, merger, reorganization, dissolution, or similar event.
 
Agents, Consultants, and Service Providers. Like many businesses, Afiniii sometimes hires other companies to perform certain business-related functions. Such third-party providers include advertising networks, data analytics providers, productivity application providers, payment processing providers, cloud storage providers, customer service platforms, and personnel management vendors.
 
Legal Requirements. Afiniii may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or enable a third party partner to comply with a legal obligation, (ii) protect and defend the rights or property of Afiniii, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
 
For California, Virginia, Colorado, Connecticut, and Utah residents, for those states’ consumer data protection laws, we do not sell your Personal Data. For residents of California, according to the California Privacy Rights Act, we do not share your Personal Data. For residents of Virginia, Colorado, Connecticut, and Utah, for those states’ consumer data protection laws, we do not use your Personal Data to engage in targeted advertising. To the extent that Afiniii collects Personal Data that constitutes “sensitive personal information” or “sensitive personal data” as those terms are defined under state law, Afiniii limits the use of such Personal Data only to the uses necessary to perform the Services.

Your Choices
 
You can visit the Site without providing any Personal Data. However, if you wish to use the Services, you must provide certain Personal Data, such as login information, to create an account or payment. If you choose not to provide certain Personal Data or agree to our Privacy Policy or Terms of Service, you will not be able to use our Service.
 
Exercising Your Rights Regarding Your Personal Data
 
We may offer choices that affect how we handle the Personal Data we control. Consistent with the laws that may apply to your residence, you may request the following concerning your Personal Data:
 
Information. You may request information about how we have collected and used your Personal Data. We have made this information available to you without having to request it by including it in this Privacy Policy.
 
Access. You may request that we confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details.
 
Correction. You may request the correction of Personal Data that is inaccurate or out of date.
 
Deletion. You may delete your Personal Data that we no longer need for lawful purposes by pressing the ‘Delete Account’ button on the user Profile page in the Afiniii application.
 
Afiniii will not discriminate against you for exercising your rights. However, a request to delete your Personal Data will include deleting your login credentials and, thus, your Afiniii account, preventing you from continuing to use the Services.
 
The following method is available to exercise your rights regarding your Personal Data.
 
-  Email admin@afiniii.com with the subject line PRIVACY REQUEST. Please indicate in the text of the email whether you are requesting the disclosure and/or deletion of Personal Data and your state of residence.
 
The following method is available to process or request the correction of your Personal Data.
 
-  From a mobile device with the Afiniii application installed, click on your user Profile, press the Edit button, make changes, and Save. You may need to authenticate your account to make changes.
 
If you submit a privacy request, Afiniii will endeavor to verify and complete your request promptly, including within the legally required response time or less. Afiniii may require additional information from you for verification purposes. Per applicable law, Afiniii will require you to re-enter your login credentials in the mobile application before we handle your request regarding your Personal Data. If we cannot verify your identity, we will not process your request regarding your Personal Data.
 
Where permitted by applicable laws and regulations, you may also submit a request regarding your Personal Data through an authorized agent. If you do so, the agent must present signed written permission from you to act on your behalf, and you may also be required to verify your identity with us independently.
 
Children
 
Afiniii prohibits anyone under the age of 16 from using the Services. Accordingly, we do not knowingly collect Personal Data from children under 16. If you are under 16, you may not create an Afiniii account or submit Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet and mobile device usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you believe a child under 16 has created an Afiniii account or provided Personal Data to Afiniii through the Services, please email us at admin@afiniii.com, and we will endeavor to delete that account and/or information after verification.
 
Exclusions
 
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Afiniii (the “Third Party Sites”). The policies and procedures described here do not apply to the Third Party Sites. The links from the Services do not imply that Afiniii endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
 
Security
 
Afiniii takes commercially reasonable steps to protect the Personal Data provided via the Services from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, no Internet, text or email transmission is ever fully secure or error-free. In particular, emails sent to or from the Services may not be secure. Therefore, you should carefully decide what information you email us. Please remember this when disclosing any Personal Data to Afiniii via the Internet.
 
Changes to Afiniii’s Privacy Policy
 
The Services and our business may change occasionally. As a result, it may be necessary for Afiniii to make changes to this Privacy Policy. Afiniii reserves the right to update or modify this Privacy Policy at any time and occasionally by posting a notice on the Site. Please review this policy periodically, especially before providing any Personal Data. This Privacy Policy was last updated on the date indicated above.
 
Contacting Afiniii
Please also feel free to contact us if you have any questions about Afiniii’s Privacy Policy or the information practices of the Services, including if you need access to our Privacy Policy in a different format. You may contact us via email at admin@afiniii.com.