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Privacy Policy

Last updated: 4 February, 2024

 

This Privacy Policy outlines how Full Circle Family Pte Ltd "Full Circle Family”, “we”, “us”) your personal information through our website – fullcircle.family, our mobile applications, our interactions with you through other modes of communication (such as SMS or instant messaging), and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

 

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. 

Interpretation and Definitions

 

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Full Circle Family Pte Ltd, 60 Paya Lebar Road.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Country refers to: Singapore

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • Service refers to the Website, mobile app, telephone communciation, SMS or instant messaging.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Website refers to Full Circle Family, accessible from www.fullcircle.family

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Our General Approach

 

Conversational artificial intelligence is at the technological frontier. We believe that this emerging technology will fundamentally change the way that we engage with and think about computers in our everyday lives. Ultimately, our goal is to use AI to build safe, smart, kind, and engaging parent assistants, companions and coaches.

Our Privacy Policy reflects our belief that achieving this goal and making the technology truly useful for all will require a deep understanding of how our users talk and collaborate with AIs. As users interact with our AIs, we learn a lot about how to make AI better and more useful to you.

Users deserve transparency regarding how that process works, particularly when it comes to their data. This Policy is one part of that transparency. It documents what data we collect, how we keep it secure, and describes how we use that data to improve our Services for everyone. Here are the top level points:

When you use our AI Parent Coach, we collect data including your name, email address, phone number, and IP address. We use this data to run the AI Parent Coach, inform improvements to the platform, keep you safe, and comply with all applicable laws.


Keeping your conversations with your AI Parent Coach private and safe is our top priority, and we will never sell or share your personal data for advertising or marketing purposes. We have strict internal controls over the use of and access to user data.
You agree to follow our Acceptable Use policy. When you talk to your AI Parent Coach, you should not try to get it to talk about harmful, abusive, or illegal topics. You also should not attempt to evade our security measures or learn about the models, algorithms, prompts, or source code of the AI Parent Coach. If our automated systems detect this activity, you may be suspended.


You are not permitted to use the Service if you are under the age of 18.


The AI Parent Coach may make up facts, events, or advice. You should never rely on anything it tells you without double-checking the facts yourself or, if appropriate, talking to a professional.

Collecting and Using Your Personal Data

Types of Data Collected

Information you provide to us

  • Contact and account information, such as your first and last name, email address, and your phone number.

  • Content and metadata of any messages that you send using the Services or to Full Circle Family directly.

  • Communications that we exchange with you, including when you respond to our surveys or contact us with questions, feedback or otherwise.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

 

Automatic data collection.

 

We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources and our communications, such as:

  • Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings and general location information such as city, state or geographic area.

  • Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Information we obtain from other sources. If you choose to contact or otherwise interact with our Services over a third-party messaging platform such as Facebook Messenger, LinkedIn, or Instagram, we will collect an identifier of your profile on these platforms.

Sensitive data. In your conversations with the Services, you may choose to provide sensitive information. This includes, but is not limited to, your religious views, sexual orientation, political views, health, racial or ethnic origin, philosophical beliefs, or trade union membership. By providing sensitive information, you consent to our use of it for the purposes set out in this Privacy Policy.

How We Use Your Information


We use personal information for the following purposes or as otherwise described at the time of collection:

Provide our Services. We use personal information to operate, maintain, and provide you with our Services. In particular, we use personal information to perform our contractual obligations under our Terms of Service.

Communicate with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, surveys, reminders, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

  1. Understanding your needs and interests, and personalizing your experience with the Services and our communications.

  2. Troubleshooting, testing, and research, and keeping the Services secure.

  3. Investigating and protecting against fraudulent, harmful, unauthorized, or illegal activity.

  4. Research and development. We may use personal information for research and development purposes where it is in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

  5. Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

  • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).

  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.

  • Enforce the terms and conditions that govern the Services.

  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

 

Sharing Your Information
 

We do not sell or share your personal information with third-parties for interest-based advertising purposes . We may disclose your personal information as described below:

  • Service providers. We may rely on third-party service providers in furtherance of the purposes described above. In these cases, personal information may be accessed by these third-parties and processed or stored on our behalf. These service providers can include hosting services, cloud computing and storage services, maintenance services, security services, and customer support services. We also may share hashes of names and phone numbers and limited device data for advertising attribution and measurement services. This means that the recipient can recognize your name and phone number only if they already have that information from another source.

  • Business transferees. Personal information may be transferred to another entity in the event of a bankruptcy, change of control, or shutdown of Full Circle Family. We may also transfer personal information in the course of a sale or merger of the business.

  • Authorities and others. If we are legally obliged or otherwise believe it necessary to do so, personal information may be disclosed to regulatory agencies, law enforcement agencies, courts, and other government authorities, including for the compliance and protection purposes described above.

Privacy Rights and Choices


Delete your account. You may request that we delete your account by contacting us as provided in the How to Contact Us section below.

 

Opt out of SMS messaging. If you wish to opt out of receiving text messages from the AI Parent Coach, reply with STOP to any mobile message sent from us. Please note that this may prevent us from sending one-time codes to your phone and may limit your experience. If you would like to allow these codes but disable all other messages, reply with PAUSE to any mobile message sent from us.

 

Online tracking technologies opt-out. You can opt out of third-party cookies as described in our Cookie Policy.

 

Personal information requests. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:Personal information requests. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:

Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

 

Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.

 

Correction of personal information that is inaccurate or out of date.

 

Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.

 

Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.


Additional rights, such as to object to and request that we restrict our use of personal information.


To make a request, please email us or write to us as provided in the How to Contact Us section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Do Not Track. Some Internet browsers can 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 http://www.allaboutdnt.com.

 

Security


Security is integral to the success of conversational AI: people need to trust that their data is being handled responsibly and safely in order to fully get the benefits of our Services.

Ensuring the integrity of your data is a major priority for us. Full Circle Family has technical measures in place to protect personal information against unauthorized access, corruption, loss, or misuse. This includes internal measures that limit access to personal information to a dedicated set of specialist employees working on improving the safety or quality of our Services. Where possible and appropriate, we also deidentify sensitive data like conversational logs to preserve user privacy.

However, these measures are not a guarantee of absolute security and you acknowledge and accept that your use of our Services is ultimately at your own risk.

Also, please note that you are responsible for managing access to any accounts that you maintain with Full Circle Family. Failure to limit access to your devices or browser might enable third-parties to have unauthorized access to your personal information.

Third-Party Websites and Content

Please be advised that you may encounter links or content through our Services that are provided by third-parties that Full Circle Family does own or otherwise control. You acknowledge that any data you provide to these third-parties shall be governed solely by the terms of service, privacy policies, and other terms applicable to those third-parties.

Children


Our Services are not intended for minors under the age of 18. We do not knowingly collect or solicit personal information from minors under the age of 18. If you are a minor under the age of 18, please do not attempt to use our Services, register an account with us, or send any personal information to us.

If you believe that a minor under the age of 18 has provided personal information to us or is otherwise using our Services, please let us know immediately at hello@fullcircle.family and we will seek to delete this information and revoke access as quickly as possible.

Retention


Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

International Data Transfers


You will provide personal information directly to our Services in Singapore. We may also transfer personal information to our affiliates, partners, and service providers in Singapore and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

Job Applicants


When you visit the careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the Services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our Terms of Service.

Changes To This Policy


We are continuing to iterate on our Services, and this Privacy Policy will need to be updated. Please be aware that we reserve the right to modify this Privacy Policy at any time.

When we do so and unless required by law to provide an alternative notice, we will post an updated version on this page. If you choose to continue your use of our Services after such a revision, you consent to be governed by the amended Privacy Policy.

 

How to Contact Us


Responsible entity. Full Circle Family is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

Please reach out to hello@fullcircle.family you have any questions or concerns pertaining to this Privacy Policy.

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