Effective Date: October 16, 2019

This Privacy Policy (“Policy”) for www.fabrica.land, the website owned by Fabrica, Inc. (“Fabrica,” “we,” “our,” or “us”), as well as the application and platform found at app.fabrica.land (collectively, together with www.fabrica.land, the “Website”) is effective as of the date written above and describes how we collect, use, disclose and otherwise process Personal Information about you when you visit our Website, submit Personal Information directly to us on the Website, apply for a job at Fabrica through the Website, or otherwise contact us or inquire about or use our products and services (collectively, together with the Website, our “Service”). This Policy also explains how we process Personal Information (“PI”) in the context of our customer, vendor, and partner relationships and the rights and choices available to individuals with respect to their Personal Information. “Personal Information” means any information relating to an identified or identifiable individual.

 

PI We Collect. We may collect PI about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your PI, as well as the consequences of failing to do so. If you do not provide PI when requested, you may not be able to benefit from our Service if that information is necessary to provide you with it or if we are legally required to collect it.

Information you provide to us directly. You may provide PI directly to us, including:

  • Identity and contact information, such as your name, address, social security number, telephone number, and email address;

  • Profile information, such as the username and password you establish with the Services;

  • Demographic details, such as date of birth, country of citizenship and/or country of residence;

  • Government-issued identification (to the extent permitted under applicable law), such as a national identification (e.g. a Social Security card, tax identification, or passport), state or local identification (e.g., a Driver’s License or other government-issued identification), and a copy of your government-issued identification card;

  • Information about real property you own or intend to purchase;

  • Financial account information, such as your bank account details and cryptocurrency wallet address;

  • Transaction information, such as details about financial transactions or investments you make with other users on our Services, including contracts you may execute (including by using your electronic signature);

  • Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services;

  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications;

  • Information about your relationship to a company, such as your job title and whether you are a beneficial owner or authorized signatory of the legal entity using the Service;

  • Other information supplied by job applicants, such as professional credentials and skills, educational and work history, and other information of the type included on a resume or curriculum vitae; and,

  • Other PI you provide to us when using the Services.

 

Information that we receive about third parties. We may receive information about individuals who do not interact with us directly. For example, our users, vendors, and partners may provide us with PI about persons other than themselves when using the Services. We require that before we are provided with PI relating to a third party, that the party providing the information has that individual’s permission or lawful authority to share it with us for processing as described in this Policy. The types of information we receive about third parties includes:

  • Information about our users’ companies, such as PI of the beneficial owners and authorized signatories of entities selling or purchasing property through the Service;

  • Information about our users’ spouses, successors and assigns, when relevant to a transaction on the Service;

  • Information about our users’ professional or financial advisors, such as the name and contact information of our users’ lawyer, accountant, broker, or other professional assisting the user;

  • Information about potential job candidates, such as when a recruiter contacts us about an individual who may become a candidate for a job at Fabrica; and,

  • Contact information of referrals submitted by our users.

 

Information we collect from vendors. We may receive information about you from our vendors. For example, we use vendors to verify the identity of users of our Service, and perform AML and KYC checks. The information we collect from vendors may include sensitive information (e.g., criminal conviction for fraud) to the extent permitted under applicable law. These vendors may provide us with information such as:

  • Whether you or your company are on government lists of restricted persons (e.g., the OFAC list or other watch lists or sanctions lists); and,

  • Whether the PI that you provided to us matches information contained in databases they consult.

 

Information we collect from private and publicly accessible sources. We and our vendors may collect information about you that is publicly available, including from county title and recording offices, publicly accessible government lists of restricted persons, public databases, media and internet searches, and others. We and/or our third-party verification providers may also collect information about you from non-public databases of third parties, to the extent permitted under applicable law.

 

Information we collect from our business partners and social media networks. We may partner with third-party companies that share PI with us. For example, if you establish a cryptocurrency wallet through one of our partners to make an investment through the Services, the provider of the wallet will share the address with us. We may also maintain pages for our company and our products on a variety of third-party platforms, such as Facebook, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Policy.

 

Sensitive Personal Information. We ask that you not send us, and you not disclose, any sensitive PI (e.g. information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic or biometric information, sexual orientation, or criminal convictions or offenses) on the Service, or otherwise to us. If you send or disclose any sensitive PI to us when you use the Service, you must consent to our processing and use of such sensitive PI in accordance with this Policy. If you do not consent to our processing and use of such sensitive PI, you must not submit such sensitive PI through our Website.

 

Information collected via automated means. We, our service providers, and our business partners may collect PI about you via automated means, such as via cookies, web beacons, embedded scripts, location-identifying technologies and similar technologies. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to the Service, general location information such as city, state or geographic area; and information about your use of and actions on our Service, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access. In addition, we collect this type of information when you read our HTML-enabled emails. Our service providers and business partners may collect this type of information over time and across third-party websites. Please refer to the Cookies and Similar Technologies section for more details.

 

Cookies and Similar Technologies. A “cookie” is a text file that a website stores on a user’s device. Our Website may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them or they otherwise expire) to provide you with a more personal and interactive experience on our Website.

 

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Website; and (2) third-party cookies, which are served by service providers or business partners on our Website, and can be used by such service providers or business partners to recognize your computer or mobile device when it visits other websites.

 

Types of cookies we use. We may use any or all of the following four types of cookies, which we describe in this section.​

  • Essential Cookies: these cookies are essential to provide you with services available through our Website and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

  • Functionality Cookies: these cookies allow our Website to remember choices you make when you use our Website. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Website.

  • Analytics and Performance Cookies: these cookies measure how often you visit our Website and how you use our Service. We use this information to get a better sense of how our users engage with our Service and how we can improve our Website and Service so that users have a better experience.

  • Targeted and Advertising Cookies: these cookies are used to collect information about your visit to our Website, the content you have viewed, the links you have followed and information about your browser, device and your IP address.

Disabling Cookies. You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” menus). Many browsers are set to accept cookies until you change your settings.

 

For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

 

If you do not accept our cookies, you may experience some inconvenience in your use of our Website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Website.

 

Other Technologies we use on our Website. In addition to cookies, our Website may use other technologies, such as pixel tags to collect information automatically. Pixel tags (which are also known as web beacons and clear GIFs) may be used on our Website and in our HTML formatted emails to track the actions of users on our Website and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Website, so that we can manage our content more effectively.

 

Do Note Track Signals. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Use of Personal Information

 

To Provide the Services. Fabrica may use your PI for the following purposes in connection with providing the Service:

  • To operate, evaluate, maintain, improve, and provide to you the features and functionality of the Service.

  • To manage identity verification of and perform KYC and AML checks on our users.

  • To process transactions you make through the Service.

  • To communicate with you regarding your account with us, if you have one, including by sending you Service related emails or messages.

  • To provide and monitor the effectiveness of our Service.

  • To monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Website and analyze data about Website traffic.

  • To diagnose or fix technology problems.

  • To tailor our Service, content and communications to you in order to provide you with a better experience.

  • To operate, evaluate and improve our business and develop new products and services.

  • For other purposes for which we provide specific notice at the time of the collection of the information.

To Manage our Recruiting and Process Employment Applications. We process PI, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

To Send you Marketing Communications. If you request information from us, register on the Website, or otherwise participate in our Service, we may send you Fabrica-related marketing communications, which may be tailored to you, as permitted by law. You will have the ability to opt out of such communications.

 

To Comply with Law. We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your Consent. We will request your consent to use your PI where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your PI, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

 

To Create Anonymous Data for Analytics. We may create anonymous data from your PI and other individuals whose Personal Information we collect. We make PI into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.

For Compliance, Fraud Prevention, and Safety. We use your PI as we believe necessary or appropriate to (a) enforce our Terms of Service (see the Fabrica Terms of Service here) that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Sharing of Your Information

We do not share or otherwise disclose PI we collect about you, except as described in this Policy or otherwise disclosed to you at the time of the collection. We may share your PI in the instances described below:

  • To comply with our legal and regulatory obligations, such as for anti-money laundering, financial and credit check, audit requirements, fraud and crime prevention and detection, and record keeping. This may include the sharing of your name, address, social security number, email address, phone number, and other PI to private third-party security providers.

  • To perpetuate and facilitate the safety and security of the Fabrica Service which includes writing records to a publicly accesible decentralized database commonly known as the Ethereum Mainnet Blockchain (“Ethereum”). This may include posting information that you provide to us, including your name, address, email address, and other PI to a publicly available database;

  • To facilitate the digital title regime created by Fabrica which involves sharing data about you in the form of a deed that is recorded at a county recorder in the county in which you own real property;

  • To facilitate the processes of the Service which allow the digital processing and storage of real property title.

 

Rights and Choice

In this section, we describe the rights and choices available to all users. Users who are located within Member States of the European Union, countries in the European Economic Area, the United Kingdom, and Switzerland (collectively, “Europe” or “European”) may read additional information about their rights below.

 

Marketing Communications. You can opt out from receiving marketing email communications from us by clicking on the unsubscribe link provided in such communications. We make every effort to promptly process all unsubscribe requests. You may continue to receive administrative messages from us, including but not limited to things like purchase confirmations, updates to our Terms of Service, and other policies.

 

Information Collected via Automated Means. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that blocking or disabling cookies may negatively impact your experience using the Website, as some features and services on our Website may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at questions@fabrica.land. We may not be able to modify or delete your information in all circumstances. In particular, any of your personal information that has been stored on Ethereum should be assumed to remain public and indestructible throughout time. Fabrica does not control Ethereum, nor does it or anyone else have the ability to delete records stored on Ethereum.

Targeted Online Advertising. Some of the business partners that collect information about users’ activities on our Website may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targetd advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

 

Choosing not to share your Personal Information. Where we are required by law to collect your PI, or where we need your PI in order to provide the Service or the Website to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required on or through the Service or through other appropriate means.

International Data Transfers

Fabrica is headquartered in the United States. Your PI may be transferred to the United States or other locations outside of your state, provice, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European users should read the important information provided in the Additional Information to European Users section about transfer of PI outside of Europe.

Data Security

We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Website. These measures are designed to appropriately protect PI against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the PI in our possession. However, no security system is impenetrable, and we cannot guarantee the security of our systems or your PI.

 

Children’s Privacy

 

We do not knowingly collect or solicit any information from anyone under the age of 16 on our Website. In the event that we learn that we have inadvertently collected Personal Information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 16, please contact us at questions@fabrica.land.

 

Links to Other Websites and Services

 

The Website may contain links to and from third party websites of our business partners and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. To the extent any features or linked websites you visit are not owned or operated by Fabrica, we are not responsible for the privacy policies or practices of those third parties.

 

How to Contact Us

 

If you have any questions about this Policy or our data practices, please contact us at questions@fabrica.land.

 

Changes to Our Privacy Policy

 

We may modify or update this Policy at any time to reflect the changes in our business and practices, and so you should review this page periodically. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on the Website. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Website.

 

Any modifications to this Policy will be effective upon posting (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.

 

Additional Information for European Users

 

Personal Information. References to Personal Information in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation.

 

Legal Bases for Processing. We use your Personal Information only as permitted by law. We are required to inform you of the legal bases of our processing of your Personal Information, which are described in the table below. If you have questions about the legal basis of how we process your Personal Information, contact us at questions@fabrica.land.

  • To provide our Services: processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

  • To communicate with you, to manage our recruiting and process employment applications, to create anonymous data for analytics, for compliance, fraud prevention and safety: these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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). In addition, we only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

  • To comply with law: processing is necessary to comply with our legal obligations

  • With your consent: processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at questions@fabrica.land.

Privacy policy