describe to you our practices regarding the personal information we collect from users of our
website located at https://flockbrain.com (the “Site”), our mobile application entitled “FlockBrain”
(the “Application”), and services (the “Services”) that enable users to find, explore and curate RSS
content that is of interest to you, and sales (the “Sales”) that gives you opportunity to buy any
product/s or service/s from our affiliates / partners.
A big part of FlockBrain is sharing content you find interesting. That’s why your FlockBrain
profile, the people and sources you follow or those follow you, the comments you post, etc., are all
1. Types of Data We Collect
We collect personal information from users, as described below.
(Tick box) giving consent for all the 3 items listed below individually.
(a ) Information You Provide to Us
When you use Services or order products on our Site or App, we will collect all information
necessary to complete the transaction, including your name, third party payment provider
information (e.g. credit card or PayPal account information), and billing information.
We may collect information about the types of news feeds (e.g. tech, business, travel, education,
etc.) that you add to or remove from the account you created to log into our network (“Account”).
We collect this information to suggest content that may be of interest to you and to tailor your
experience to meet your special interests.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail
address, as well as any other content included in the e-mail, in order to send you a reply.
If you participate in a sweepstakes, contest or giveaway on our Site, we may ask you for your
e-mail address and/or home number (to notify you if you win or not). We may also ask for first
and last names, and sometimes post office addresses to verify your identity. In some situations we
may need additional information as a part of the entry process, such as a prize selection
choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each
sweepstakes and contest that you enter.
We may also collect personal information, such as at other points in our Service that state that
personal information is being collected.
(b) Information You Provide to Facebook and other Social Networking Sites
The Services allow users to access Facebook to interact with friends and to share on Facebook
and/or Google+ through friends’ news feeds. When you click on “Personalize with Facebook,” or a
similar connection on another social networking service (each, an “SNS”), you will be prompted to
enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Services
use of the Services. In this case, we may receive information from Facebook or another SNS to make
it easier for you to create an Account on the Site and show our relevant content from your Facebook
or SNS friends. Once you register on the Site and connect with Facebook or another SNS, you will be
able to automatically post recent activity back to Facebook or the other SNS. Any information that
we collect from your Facebook or other SNS account may depend on the privacy settings you have with
that SNS, so please consult the SNS’s privacy and data practices. You have the option to disable the
connection between the Services and your SNS account at any time by logging into your Account
through the Site and going to settings, “About Me,” “Linked Accounts,” and then unselecting your
(c) Information Collected via Technology
Log Files. As is true of most websites and mobile applications, we gather certain information
automatically and store it in log files. This information includes IP addresses, browser type,
Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and
clickstream data. We use this information to analyze trends, administer the Site, track users’
movements around the Site, gather demographic information about our user base as a whole, and
link this automatically collected data to personal information.
(Tick Box) I understand and give my consent to the use of information from my mobile/ website.
Mobile Services. We may also collect non-personal information from your mobile device if you have
downloaded our Application. This information is generally used to help us deliver the most relevant
information to you. Examples of information that may be collected and used include how you use the
Application, and information about the type of device you use. In addition, in the event our
Application crashes on your mobile device, we will receive information about your mobile device
model software version and device carrier, which allows us to identify and fix bugs and otherwise
improve the performance of our Application. This information is sent to us as aggregated information
and is not traceable to any individual and cannot be used to identify an individual.
(Tick Box) I understand and give my consent to the use of information from my mobile
pieces of information that a website sends to your computer’s hard drive while you are viewing the
website. We may use both session Cookies (which expire once you close your web browser) and
persistent Cookies (which stay on your computer until you delete them) to provide you with a more
personal and interactive experience on our Service. This type of information is collected to make
the Service more useful to you and to tailor the experience with us to meet your special interests
PixelTags. In addition, we use “PixelTags” (also referred to as clear Gifs, Web beacons, or Web
bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies
that are used to track online movements of Web users. In contrast to Cookies, which are stored on a
user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow
us to send e-mail messages in a format users can read, and they tell us whether e-mails have been
opened to ensure that we are sending only messages that are of interest to our users. We may use
this information to reduce or eliminate messages sent to a user. We do not tie the information
gathered by Pixel Tags to our users’ personal information.
Traffic Analytics. We use a number of third party service provides, such as Google Analytics, to
help analyze how users use the Service (“Analytics Companies”). These Analytics Companies uses
Cookies to collect information such as how often users visit the Service, what features they use on
our Application, and what other sites they used prior to coming to the Site. We use the information
we get from these Analytics Companies only to improve our Site, Application and Services. These
Analytics Companies collect only the IP address assigned to you on the date you visit the Service,
rather than your name or other personally identifying information. We do not combine the information
generated through the use of our Analytics Companies with your personal information. Although these
Analytics Companies may plant a persistent Cookie on your web browser or mobile device to identify
you as a unique user the next time you visit the Service, the Cookie cannot be used by anyone but
the Analytics Company that placed the applicable Cookie. This Policy does not apply to and we are
not responsible for the Cookies used by these Analytics Companies.
Note that the basis for this collection and processing of your personal data is to perform the
contract with you related to these activities and services or because you have asked us to take
specific steps before entering into a contract in respect to these activities and services.
2. Use of Your Personal information
(a) General Use
In general, personal information you submit to us is used either to respond to requests that you
make, or to aid us in serving you better. We use your personal information in the following ways:
facilitate the creation of and secure your Account on our network;
identify you as a user in our system;
provide improved administration of our Application and Services;
provide the Services you request;
improve the quality of experience when you interact with our Application and Services;
Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account
send you administrative e-mail notifications, such as security or support and maintenance
respond to your inquiries related to employment opportunities or other requests;
send newsletters, surveys, offers, and other promotional materials related to our Services and
for other marketing purposes of Company.
This processing is necessary for the administration of our business and the provision of our
services, which is necessary for the legitimate interests of our business.
(b) User Feedback
We often receive comments from users who have had positive experiences with our Services. We may
post user feedback on the Site from time to time. We will share your feedback with your first name
and last initial only. If we choose to post your first and last name along with your feedback, we
will obtain your consent prior to posting your name with your feedback.
(c) Creation of Anonymous Data
We may create anonymous data records from personal information by excluding information (such as
your name) that makes the data personally identifiable to you. We use this anonymous data to analyze
request and usage patterns so that we may enhance the content of our Services and improve
Application navigation. We reserve the right to use anonymous data for any purpose and disclose
anonymous data to third parties in our sole discretion.
3. Disclosure of Your Personal information
We disclose your personal information as described below and as described elsewhere in this Privacy
(On/Off choice) giving consent or withdrawing consent for all the items listed below individually.
(a) Third Parties Designated by You
When you use the Services, the personal information you provide will be shared with the third
parties that you designate to receive such information.
(b) FlockBrain Business
If you subscribe to our “FlockBrain Business” service, you may curate and share content with other
users of the Services who have linked their Accounts to your FlockBrain Business Account
(collectively such members who have linked their Accounts (pursuant to the processes described in
our Terms of Service) to your Account are your “Team”). If you subscribe to FlockBrain Business, we
will share the content you curate via the Services (“Curated Content”) with the other members of
your Team. We will not sell your Curated Content to any third party.
(c) Third Party Service Providers
We may share your personal information with third party service providers to: provide you with the
Services that we offer you through our Site; to conduct quality assurance testing; to facilitate
creation of accounts; to provide technical support; and/or to provide other services to the Company.
These third party service providers are required not to use your personal information other than to
provide the services requested by the Company.
(d) Social Networking Sites
or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with
your elections. You acknowledge and agree that you are solely responsible for your use of those
third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or
accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or
(iii) your use of any such SNSs.
(e) Corporate Restructuring
We may share some or all of your personal information in connection with or during negotiation of
any merger, financing, acquisition or dissolution, transaction or proceeding involving sale,
transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of
an insolvency, bankruptcy, or receivership, personal information may also be transferred as a
business asset. If another company acquires our company, business, or assets, that company will
possess the personal information collected by us and will assume the rights and obligations
(f) Other Disclosures
Regardless of any choices you make regarding your personal information (as described below), Company
may disclose personal information if it believes in good faith that such disclosure is necessary (i)
in connection with any legal investigation; (ii) to comply with relevant laws or to respond to
subpoenas or warrants served on Company; (iii) to protect or defend the rights or property of
Company or users of the Application or Services; and/or (iv) to investigate or assist in preventing
4. Your Choices Regarding Your Information.
You have several choices regarding use of information on our Services:
(On/Off choice) giving consent or withdrawing consent for all the items listed below individually.
(a) Email Communications
We will periodically send you free newsletters and emails that directly promote the use of our Site,
Application or Services. When you receive newsletters or promotional communications from us, you may
indicate a preference to stop receiving further communications from us and you will have the
opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you
receive or by contacting us directly (please see contact information below). Despite your indicated
e-mail preferences, we may send you service related communications, including notices of any updates
(b) Changing or Deleting Your Personal Information
You may change any of your personal information in your Account by clicking the “Erase account” text
within the “Organize” page of your Account or by visiting FlockBrain.com/i/erase and following the
directions therein. You may requested deletion of your personal information by us, and we will use
commercially reasonable efforts to honor your request, but please note that we may be required to
keep such information and not delete it (or to keep this information for a certain time, in which
case we will comply with your deletion request only after we have fulfilled such requirements). When
we delete any information, it will be deleted from the active database, but may remain in our
archives. We may also retain your information for fraud prevention or similar purposes.
Under the GDPR, it's important that you don't store personal data for longer than you need it. (What
is the time duration we keep the data with us?)
(c) Data Collection
You can stop all collection of information by the Application 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.
5. Security of Your Personal information
Company is committed to protecting the security of your personal information. We use a variety of
industry-standard security technologies and procedures to help protect your personal information
from unauthorized access, use, or disclosure. No method of transmission over the Internet, or method
of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to
protect your personal information, Company cannot guarantee its absolute security.
The most current version will govern our use of your information and will always be posted on the
websites and apps to which this policy applies, and older versions are available upon request. If we
make changes that we think will substantially alter your rights, we will notify you by posting a
notice on our website. Your continued use of our websites, apps, or services means that you consent
(Tick Box) I have read, understood and accepted to the changes/revisions/updates to the privacy
7. Your California Privacy Rights.
If you reside in California, you have the right to ask us one time each year if we have shared
personal information with third parties for their direct marketing purposes. To make a request,
please send us an email, or write to us at the address listed below. Indicate in your letter that
you are a California resident making a “Shine the Light” inquiry. If you reside in California, you
can make the following more specific requests in addition with respect to your personal information:
Access – You can request that we disclose to you the categories of personal information we
collected about you, the categories of sources from which we collected the personal information,
the categories of personal information we sold or disclosed, our business or commercial purpose for
collecting and selling the personal information, the categories of third parties with whom we shared
the personal information, and the specific pieces of personal information we collected about you
over the past 12 months. California residents can make this request online by emailing us at
Deletion – You can request that we delete your personal information that we maintain about you,
subject to certain exceptions. California residents can make this request online by emailing us at
Do Not Sell My Info – You can request that we not sell your personal information by clicking Do Not
Sell My Info on the website and in the app in the Privacy section of the Settings menu or by
“sell” means the sale of your personal information to an outside party for monetary or other
valuable consideration, subject to certain exceptions set forth in applicable California law. Please
note that any opt-outs through these tools are specific to the device and browser you are using,
so you should opt-out for each web browser and on each device you use. Your opt-out preferences will
be deleted any time you clear your web browser’s cookie cache.
If you have a FlockBrain account, on the website or on mobile app you can log into your account and
navigate to Privacy Settings to opt-out of the sale of your personal information.If you do not have
a FlockBrain account and only visit FlockBrain.com, we have limited information about you and do
not “sell” your information as described in this policy.
Ifyou do not have a FlockBrain account but use the FlockBrain mobile app, you can navigate to
Privacy Settings in the FlockBrain app to opt-out of the sale of your personal information.
However, you may also be able to configure your mobile device privacy or advertising settings,
including by selecting “limit ad tracking” on an iOS device or “opt out of interest-based ads” on an
You may also opt-out of sale in some instances by using the DAA CCPA Opt Out Tool at
https://optout.privacyrights.info/?c=1. In addition you may be able to opt-out of some – but not all
– interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices
and downloading the mobile AppChoices app. To opt-out of cookie-based tracking for advertising
purposes, you will also need to separately visit https://optout.aboutads.info/ and
FlockBrain is not intended for users under the age of 16. We do not knowingly collect information
from anyone under the age of 16. Please see our section on Minor Children for more information.
FlockBrain will not discriminate against you because you made any of these requests. We may deny
certain requests, or fulfill a request only in part, based on our legal rights and obligations. For
example, we may retain personal information as permitted by law, such as for tax or other record
keeping purposes, to maintain an active account, and to process transactions and facilitate customer
does not include information about job applicants, employees and other of our personnel; information
about employees and other representatives of third-party entities we may interact with; or
information we have collected as a service provider to our clients. We will take reasonable steps to
verify your identity prior to responding to your requests. For example, we may utilize a third party
verification provider to assist with verifying your identity. The verification steps may vary
depending on the sensitivity of the personal information and whether you have an account with us.
California residents may designate an authorized agent to make a request on their behalf. When
submitting the request, please ensure the authorized agent is identified as an authorized agent. If
you are an authorized agent submitting a request on behalf of a California consumer please email
email@example.com. For purposes of California residents making these requests, please also note
the following regarding how we collect, use, and share your personal information as described in
We may collect, use, and disclose for our business and commercial purposes as described above,
categories of personal information as set forth in applicable California law, including:
Identifiers, Contact and Account Information, Payment Information, Demographic Information,
Information You Submit, Device, Internet, and Network Activity Information, Location Information,
Employment Related Information, and Inferences.
We collect these categories of personal information from the sources described above, including
directly from you, advertising partners and networks, data analytics providers, vendors and
service providers, data brokers, social networks, third party publishers, our business and
marketing partners, and other parties in connection with business transfers and for legal, safety,
fraud prevention, and enforcement reasons.
We may disclose each of the foregoing categories of personal information for the business and
service providers and suppliers; our business and marketing partners, including advertising
networks, data analytics providers, data brokers, and social networks; and other parties in
connection with business transfers and for legal, safety, fraud prevention, and enforcement
We may “sell” categories of personal information, including: Identifiers, Contact and Account
Information, Demographic Information, Information You Submit, Device, Internet, and Network Activity
Information, Location Information, Employment Related Information, and Inferences. We may “sell”
these categories of personal information to the categories of third parties described in this
analytics providers, data brokers, and social networks.
8. Data Storage Outside the EU
As a California-based company, we store and use personal data outside the EU. By using our websites
or submitting your personal data, you consent to such transfer, storing and processing. To ensure
adequate protection of personal data in cross-border transfer and/or processing, we use appropriate
safeguards as allowed under applicable law or regulation.
9. Compliance to GDPR’s legal bases to process a person’s personal data:
The GDPR applies to businesses that collect and use personal information from residents of the EU,
regardless of where the business itself is located. This gives the GDPR a global reach.
It is considered unlawful under the GDPR to collect so much as an IP address or device identifier
from an EU resident without a legal basis for processing that data. (Need more clarity on our case)
10. Contact Company
Our Data Protection Officer is responsible for overseeing what we do with your information and
monitoring our compliance with data protection laws. (As per GDPR)
or processing practices, or if you want to report any security violations to us, please contact us
at the following address or phone number:
Legal Department or DataPrivacyOfficer@flockbrain.com
(Address of Registered office)
11. A Note About Children
We do not intentionally gather personal information from visitors who are under the age of 16 years,
If we come to know that a child under 16 years is using our services, we’ll immediately block the
child from using our website/App/services and we terminate the child’s account delete all
information collected pertaining to that child immediately from our data-storage without any notice.