Privacy Policy

313RED Privacy Policy

This Privacy Policy was last modified on April 5, 2024.

313RED protects and connects your loved ones, pets, and important items to make your life easier and less stressful. We take your privacy as seriously as you do, and we are committed to protecting it.  This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our products and services, as well as your choices regarding the same. 

As you review our policy, keep in mind that it applies to 313RED, Inc.’s ("313RED", "we", "our", or "us") websites, mobile apps (313RED, FaithGuardian and FaithLend), help center and other associated services we provide (“Services”).  It also applies to 313RED physical devices (FaithGiving) as well as other products (“Products”).  

Before accessing or using our Products and/or Services, please ensure that you have read this Policy and understand how we collect, store, use, and disclose your personal information as described herein.

Table of Contents

I. INFORMATION WE COLLECT

1. Information You Give Us Directly
2. Information We Collect when You Use or Interact with our Products and Services
3. Information Provided to Us by Third Parties

II. HOW WE COLLECT INFORMATION

1. Cookies and Similar Technologies
2. Analytics and Advertising Technologies

III. HOW WE USE YOUR INFORMATION

1. Administrative Purposes
2. Marketing 313RED Products and Services
3. Research and Development
4. Connecting with Social Media
5. Information Collected Automatically Through the use of Tracking Technology

IV. INFORMATION WE DISCLOSE TO THIRD PARTIES

1. Disclosing to Others in Your 313RED FaithGuardian Account, or Friends
2. Information Posted to our Blogs, Community Forums or Other Public Websites
3. Service Providers, Business Partners and Advisors
4. Purchasers and Other Third Parties in Connection with a Business Transaction
5. Law Enforcement, Regulators and Other Parties for Legal Reasons
6. De-Identified Information

V. YOUR CHOICES ABOUT YOUR INFORMATION

1. Modifying, Correcting, Reviewing and Deleting Your Information
2. Communications from 313RED
3. Location and Movement Data Collection and Sharing in the 313RED App
4. Web-Based Personal Information Sales

VI. OUR POLICY TOWARDS CHILDREN

1. Setting up a Child Account
2. Personal Information we Collect about Children
3. Information sharing about Children
4. Contact Us Regarding your Child’s Account or Information

VII. HOW WE PROTECT YOUR INFORMATION

1. Security
2. Accuracy and Confidentiality of Your Email Address and Password
3. Fraud Prevention
4. Onward Transfer
5. Data Retention

VIII. ADDITIONAL STATE, COUNTRY AND REGION-SPECIFIC PRIVACY TERMS

1. California Consumer Privacy Act (CCPA) and California Consumer Rights Act (CPRA)
2. Legal Basis for Processing
3. California’s “Shine the Light” Law
4. Your Nevada Privacy Rights
5. International Transfer

IX. LINKS TO OTHER WEB SITES AND SERVICES

X.CHANGES TO THIS PRIVACY POLICY

XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

   

I. INFORMATION WE COLLECT

The information 313RED collects depends on what 313RED Products or Services you use and how you use them. Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services.

A. Information You Give Us Directly

When you create or modify a 313RED, FaithGuardian, FaithMarket or FaithLend account, update your preferences, purchase and/or activate a Product, contact us (including by social media or via our Help Center), participate in an online survey, or otherwise interact with 313RED’s Products and Services, we may collect a variety of information, including:

• Account Information. Your username, email address, real name, nicknames, date of birth, telephone number, password, shipping and billing addresses, and Products activated. You may also choose to provide a photo to associate with your 313RED account, FaithGuardian, FaithMarket or FaithLend Products.
• FaithGuardian Information. When you create a FaithGuardian in your 313RED app and invite a friend or family member to join your FaithGuardian, we collect their name, email address, mobile phone number, and photo if one is provided.
• Identity Verification. In certain circumstances, for instance, depending on the features of our Products and Services you use or based on your age and country of residence, we may collect additional information to verify that a parent or guardian has consented to use of the Services by a child. This information may include information from or an image of government-issued ID, an image (for example, a selfie) which may be used with facial recognition technology. (Note: the digital age of consent may vary by jurisdiction and 313RED may adjust our parental consent process accordingly.).
• Payment and Transaction Information. When you place an order for a Product or upgrade to a premium subscription or Give donation, you’ll need to provide an email address, a first and last name and/or a shipping address. Any payment information provided is processed by the relevant billing and/or payment processor. We may also collect information such as which version of the Product or subscription service you are using, the date and time that you activated your account, the duration of your subscription, the data related to any subscription cancellation request, and any in-app purchases you may make.
• Optional Account Information. We may collect information when you customize features within our Products (for example, labeling locations on your in-app map within 313RED FaithGuardian).
• Contest Prize and Tax Information. If you are the recipient of a contest or sweepstakes prize that requires tax reporting, we may collect identifiers associated with your government-issued documents (such as a social security number).

• Other Information You Provide to Us. Information you provide in response to surveys about our Products or Services, any information about your friends that you provide us through our referral services, information you provide when seeking help from us, such as your name, email address, telephone number, mailing address and records (including call recordings) and technical information related to the issues you experience.

B. Information We Collect When You Use or Interact with our Products and Services

We may collect other information when you use our Products and Services, such as:

• Device Information. Information about your device, hardware and software information, such as your mobile device identifiers, IP address, or browser information (including browser type and language preference).
• Location and Movement Information. We collect your location and motion information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device, motion information such as altitude, heading and speed.
• Driving Event Information. We may collect sensory and motion data from your mobile device, including gyroscope, accelerometer, compass, and Bluetooth (including information related to your motion activity, such as whether you are cycling, walking, running, or driving, and information about your speed, acceleration, and deceleration).
• Messages and Member Content. We collect information when you message other members on FaithGuardian through use of our Services, when you provide 313RED with feedback, when you make a blog post, comment, or when you tag 313RED, FaithGuardian, in a social media post, any photos or videos you send via the in-app messaging to other members of your FaithGuardian account.

C. Information Provided to Us by Third Parties

We may receive information about you from other sources, including through third-party services that you connect to your 313RED account, or third-party services and organizations to supplement information provided by you. For example:

• When you link your FaithGuardian account to a smart partner platform to enable interaction with our Products and Services through voice or other smart platform interactions or services (e.g. Google Assistant-enabled or Alexa-enabled devices), we may collect location information for all FaithGuardian account members scanned by the smart partner device for members who have linked their account to the applicable platform.
• When you choose to connect or interact with our Services through a third-party social networking service (“Social Network”), such as when you Like us on Facebook or post a comment to our Facebook page, we may collect information that you have already made public on your Social Network account.
• We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your personal Social Network account such as your name, your Social Network user identification number, your Social Network username, location, gender, birth date, email, profile picture, and your contacts on the Social Network. 

II. HOW WE COLLECT INFORMATION

When you visit our websites, use our apps, read our emails or otherwise engage with us, we may automatically collect certain information about your device through a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “Tracking Technologies”), and we may combine this information with other personal information we collect about you. We use these Tracking Technologies to collect usage and device information, such as:

• Information about the computer, tablet, smartphone or other device you use, for example, your device’s IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, whether the device is connected to WiFi, and other such information. With your permission, we may also access your photo or camera roll.

We also use Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may utilize the same Tracking Technologies or similar mechanisms as further described below.

A. Cookies and Similar Technologies

Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. 

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail).

For more information about the Cookies we use and how to manage their setting please click on “Do Not Sell or Share My Personal Information” at the bottom of any of our web pages.

B. Analytics and Advertising Technologies

We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites, Products and Services. Some of the types of data that analytics technologies may capture are as follows:

• referral/exit pages; 
• how frequently you access our Services; 
• whether you open emails or click the links contained in emails; 
• whether you access our Services from multiple devices; 
• the features you use; 
• the links you click; 
• the ads you view and click on; 
• purchase transaction information; 
• your location when you access or interact with our Products and Services; 
• technical related information about your computer or device and operating and/or network systems (such as IP Address and device ID);
• performance data (such as app launch time, hang rate, or energy usage);
• information about your engagement with certain features and usage statistics (including app launch taps and interaction information like video views); and 
• other similar actions.

In addition to the above, we may collect and share your personal information, including your unique identifiers or Advertising IDs and other data such as app events, with our Service Providers and Business Partners, third-party ad networks, and Social Networks, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes. 

These advertising partners may collect and use additional information such as:

• click stream information; timestamp; hashed email address; device ID or AdID; and
• information related to your use of third-party applications;

and may combine this information with information they collect directly through Tracking Technologies or that they receive from other third parties. These third-party partners may use the information they have gathered independently according to their own privacy policies.

You have the right to object to and opt out of certain third-party tracking and advertising. Where you have consented to 313RED’s processing of your information, you may withdraw that consent at any time and opt out of certain processing activities, such as targeted marketing communications (this may not include opting out of seeing in-app advertisements). Even if you opt out, we may still collect and use information regarding your activities on our websites and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements. For more information on how to adjust your third-party tracking and advertising settings please see the following informational pages:

Opt-out of 313RED sharing data with third-parties for advertising purposes on our websites
To help our members be in control, we offer members the ability to make choices regarding the collection and use of personal information via tools on our websites. 

Browser-Based Global Privacy Controls and Do Not Track Signals
Our websites (Life360.com, Tile.com, Jiobit.com, or support pages) respect Global Privacy Controls (GPC) and Do Not Track (DNT) browser signals that you have configured within the settings menu of your browser. 

Website-Based Privacy Controls
If you have visited any of our websites (Life360.com, Tile.com, Jiobit.com, or support pages) or plan to visit in the future, you can opt out of web-based personal information sales by following the below instructions: 

1. Navigate to our website
2. Scroll to the bottom of the page,
3. Click on the “Do Not Sell or Share My Personal Information” link in the website’s footer,
4. Then move the “Targeting Cookies” and “Social Media Cookies” toggles to the OFF position, and
5. Then click on the “Save and Close” button.

This is a web-based choice only, and does not affect app-based personal information sales or sharing. In addition, this opt-out is specific to each of our websites and your browser and device and may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another device, you will need to opt out again. Note: Some third-party data partners may continue to send you personalized or location-based ads based on your previous location(s) or data they have collected from other websites and mobile apps.

Limit information sharing with third-party partners through in-App privacy settings
The 313RED app provides several mechanisms for our members to out-out of sharing personal information (including location and movement data) with our partners for targeted advertising, research, attribution, and similar purposes.

Members using the 313RED App:
iOS device users may opt-out by selecting “Ask App Not to Track” upon installation of the 313RED app on your device or by following the below instructions. Members may opt-out of app-based personal information sales at any time by following these steps in the 313RED app:

• Log into your account on the 313RED mobile app on your device
• Open the app and navigate to the "Settings" menu
• Tap on "Privacy & Security"
• Tap on “Do Not Sell or Share My Personal Information”
• Then move the “Personal Information Sales” toggle to the OFF position

You must follow these in-app steps for each person in your Circle as the “Do Not Sell or Share My Personal Information” option is limited to the data for the account logged in at the time of the request.

Effect of Opting-Out:
If you opt-out, using Apple’s App Tracking Transparency framework or the “Personal Information Sales” toggle within the 313RED App, 313RED will continue to collect your device location and movement data and to share such information with your Circles and with third parties as needed to support and provide the 313RED Services or other services you engage, but we will no longer share information about you with our third party partners for their own advertising and other commercial purposes. Please note, some third party partners may continue to send you location-based ads based on your previous location(s) or may approximate your location based on other information they may have collected.

To Opt-In to Personal Information Sales:
Members may opt-in to app-based personal information sales at any time by following these steps in the 313RED app:

• Log into your account on the 313RED mobile app on your device
• Open the app and navigate to the "Settings" menu
• Tap on "Privacy & Security"
• Tap on “Do Not Sell or Share My Personal Information”
• Then move the “Personal Information Sales” toggle to the ON position

If you are an iOS device user and have previously opted-out of personal information sales and sharing by clicking on “Ask App Not to Track” upon installation of the 313RED app and wish to opt-in to personal information sales and sharing utilizing the “Personal Information Sales” toggle, you must first re-enable app tracking under your device’s Privacy & Security Settings and then toggling “Personal Information Sales” to ON within the 313RED app.

Interest-based advertising via a Web Browser
To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to tailor and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, and/or the Digital Advertising Alliance’s resources. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices. 

Please note that opting-out of receiving interest-based advertising through the Network Advertising Initiative’s and Digital Advertising Alliance’s online resources will only opt-out a member from receiving interest-based ads on the specific browser or device used to action the opt-out, and the member may still receive interest-based ads on their other devices or when using different browsers. You must perform the opt-out on each browser or device you use.

California residents may also opt out of the sale of your personal information (including Internet/Network Information, Commercial Information and Inferences) by third party advertising networks, social media companies and similar online advertising companies for targeted online advertising purposes. By visiting the California Consumer Privacy Act Opt-Out Tool, you can opt out from sales of this type of personal information by businesses that implemented the use of this opt out tool.

Mobile advertising;
You may be able to limit interest-based advertising through the privacy and ad preferences settings on your mobile device. In addition, you may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks who are a part of the Digital Advertising Alliance or that have implemented the Digital Advertising Alliance’s mobile AppChoices app.

Google Analytics and advertising
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services. 

For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising the Network Advertising Institute’s online resources at http://www.networkadvertising.org/choices.

III. HOW WE USE YOUR INFORMATION

We may use your information to provide, maintain, and improve our Products and Services to develop new products and features, to determine which new products or services may be of interest to you and to promote our Products and Services, and we may disclose your information to our Service Providers and Business Partners for these purposes.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information for our business purposes and as permitted by applicable law.

The specific purposes for our acquisition, retention, use, and processing of your information are described in this Section III (How We Use Your Information). 

A. Administrative Purposes

We may use information about you for our administrative purposes, including to:

• Provide the Products and Service to you;
• Measure interest in 313RED’s Products and Services; 
• Develop new products and Services; 
• Ensure the integrity, security and perform internal quality control and optimization of our Products and Service; 
• Verify individual identity; 
• Communicate about individual accounts and activities utilizing 313RED’s Products, Services, and systems;
• Make changes to any 313RED policies; 
• Send messages to the email address you provide to us to verify your Account; 
• For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance; 
• To process payment for products or services purchased; 
• To process applications and transactions; 
• To prevent potentially prohibited or illegal activities; and 
• To enforce our Terms of Use and this Privacy Policy.

B. Marketing 313RED Products and Services

313RED may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:

• Provide you with information related to 313RED’s or our business partners’ products and services that may be of interest to you;
• Notify you of upcoming special offers/events we believe may be of interest;
• Conduct online behavioral advertising;
• Tailor content, advertisements, and offers that may be of interest to you; 
• Introduce new content, features, Products or Services.; and 
• For other purposes disclosed at the time that you provide us your information; or otherwise with your consent. 

C. Research and Development

We may use information to create non-directly identifiable information that we may use alone or in the aggregate with information obtained from other sources as set forth herein, in order to:

• Conduct individual or market research;
• Conduct research and drive marketing analytics;
• Help us to optimally deliver our existing Products and Services;
• To develop new Products and Services; and
• For research and internal analysis.

For instance, from time to time, 313RED may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf (all survey responses are voluntary). The survey responses may be utilized to:

• Determine the effectiveness of our Products and Services, 
• Perform various types of communications, advertising campaigns, and/or promotional activities; and
• Learn more about our members and potential members and their individual and collective needs.

If an individual participates in a survey, the information given may be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.

D. Connecting with Social Media 

When you choose to connect or interact with our Services through a Social Network, or if you use Social Features, the information provided to 313RED via those Social Networks or Social Features may be used to verify information that you have independently provided to 313RED and to enhance our ability to provide you with information about our business, products, and Services.

These Social Features are operated solely by the respective Social Networks, and their service providers, and we recommend that you carefully read their privacy policies before you decide to use them. We have no control over or access to the information collected, stored or used by such Social Networks, and the information practices of such Social Networks are not covered by this Privacy Policy.

E. Information Collected Automatically Through the use of Tracking Technology

We use information collected through the use of Tracking Technologies (e.g., cookies and web beacons) for our business purposes, or similar, including to: 

• Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services; 
• Authenticate your access;
• Keep track of your in-app specified preferences or choices;
• Display a personalized browsing history
• Provide custom, personalized content and information, including targeted content and advertising;
• Record your device’s location and movements; 
• Identify and contact you across multiple devices; 
• Provide and monitor the effectiveness of our Services and our marketing campaigns; 
• Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns; 
• Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs;
• Detect or prevent fraud or other harmful activities; 
• Automatically update our mobile application on your system and related devices; and 
• Otherwise plan for and enhance our Services.

IV. INFORMATION WE DISCLOSE TO THIRD PARTIES

We may disclose your information to select third parties as well as our subsidiaries as set forth herein.

We may also disclose this information within 313RED, with our subsidiaries, and with third parties for our or their purposes in an anonymized or aggregated form.

A. Information Posted to our Blogs, Community Forums or Other Public Websites

Any information or content that you voluntarily submit, or post to the 313RED or FaithGuardian websites or blogs, community forums, or comments you post to our Facebook page (or other social media pages) will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third-party websites.

We are not responsible for any information you choose to provide on social media pages, or for any content or communications you receive as a result of sharing such information.

B. Service Providers, Business Partners, and Advisors

We may disclose your personal information to our vendors and consultants who help us provide our Services or who perform services on our behalf, such as accounting, managerial, technical, email or chat services, marketing or analytic services, fraud prevention, bot detection, web hosting, and to other third-party partners or Service Providers to provide services or features to our members on our behalf or on behalf of our permitted business partners. 

We may disclose personal information, including contact information and location and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device), application analytics (including IP address and device identifiers), technical and analytical data, and driving event data with third-party partners that provide certain features and services you elect to use through or in connection with our Products or Service, to the extent that they are available in your country or region of residence.

We will never disclose your telephone number (in a non-obfuscated format) with any of our third-party business partners, vendors, or consultants for their independent SMS marketing purposes without your explicit, affirmative opt-in consent.

C. Purchasers and Other Third Parties in Connection with a Business Transaction

We may at any time buy or sell/divest the company, or any portion or combination of its products, services, assets and/or businesses. Personal information such as member names and email addresses, and other member information related to our Services will likely be one of the items transferred in these types of transactions. We may disclose, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings.

D. Law Enforcement, Regulators, and Other Parties for Legal Reasons

We may disclose personal information to third parties (including but not limited to, law enforcement, other government entities, or civil litigants) when required to do so by law or subpoena, or if we determine (in our sole discretion) that disclosure is necessary to: (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Service, this Privacy Policy, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of 313RED, our employees, members or others.

E. De-Identified Information 

Some third parties provide important services to us as our service providers and have rights to commercialize solely aggregated data for certain purposes. We may share with third parties, including advertisers, Business Partners, and Service Providers, anonymized, aggregated and/or anonymous data we collect about you and other members, such as de-identified demographic information, de-identified location information, and information about the computer or device from which you access our Services, or the results of hashing your email address.

V. YOUR CHOICES ABOUT YOUR INFORMATION

We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored and shared as outlined in this Section V (Your Choices about Your Information).

A. Modifying, Correcting, Reviewing, and Deleting Your Information

You may modify your account information, update or amend your personal information (e.g. name, email address, or phone number), or change your password by logging in to your App, clicking on “Me” and then “Edit Your Account” (for 313RED) or “Settings” (for FaithGuardian). 

You may review the information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties with whom we disclose personal information, or request that your information be deleted by submitting a request as described below. Please note that the information provided via the in-App links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at privacy@313.red).

In the 313RED app, you may:

• Exercise your right to Opt In or Opt Out of App-based personal information sales or sharing by clicking on the “Do Not Sell or Share My Personal Information” link in your in-App Privacy & Security settings and adjusting the personal information sales toggle. 
• Request a copy or deletion of your personal information under the “Additional Data Rights” page, then, select “Request Your Personal Information” or “Delete Your Account” to submit your request. We will process your request and send a confirmation email. 

In the FaithGuardian app, you may:

• Request deletion of your personal information through the FaithGuardian app by clicking on “Family” and “Following”, and finally by clicking on “Delete Account” and following the on-screen instructions.
• Request deletion of your personal information by clicking on “Menu”, then “Account”, then “Manage Account, and finally by clicking on “Delete My Data” and following the on-screen instructions.
• To exercise your other rights related to the FaithGuardian Products and Services please contact us as further described below with your detailed request. 

You may also request the closure and deletion of your account by contacting us at  privacy@313.red with your deletion request. Please include your full name, the email address associated with your Account, the service you are using, and a detailed description of your deletion request. 

Note: Prior to deletion of your FaithGuardian account, you may transfer your FaithGuardians to another FaithGuardian customer by following the instructions found in our support pages covering the Transfer of a FaithGuardian. FaithGuardians may only be transferred from or to active accounts.

For FaithGuardian customers: If you delete your account or other personal information, the location information associated with active FaithGuardian Products may still be collected anonymously from other FaithGuardian Community members who are running the app and are within Bluetooth range of your device. To completely disable this type of information collection we recommend you transfer the FaithGuardian prior to account or data deletion, remove the battery from or disable your Products.

B. Communications from 313RED

We may periodically send you promotional newsletters and emails. You have the ability to opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates are necessary for you to receive, you will not be able to opt-out of those communications. For more information about the types of communications 313RED may send, and for detailed instructions on how to opt-out please see the following:

Email and Telephone Communications;
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt and within timeframes required by law. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding 313RED and our Products and/or Services and you will not be able to opt out of those communications (e.g., account verification, parental consent notification, order confirmations, change or updates to features of our Services, technical and security notices and communications regarding updates to our Terms or this Privacy Policy).

You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law. 

Mobile Devices and In-App Messaging
313RED may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by visiting “Settings” within the 313RED mobile app.

“Do Not Track”, Cookies and Web Beacons
Do Not Track (“DNT”) is a privacy preference that members can set in certain web browsers. DNT is a way for members to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. 

If you prefer not to accept cookies, most browsers will allow you to:

• change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; 
• disable existing cookies; or 
• set your browser to automatically reject cookies. 

We have also provided you with easy access to our Privacy Preference Center through links at the bottom of every 313RED (313RED, Tile, and support) web page entitled: “Cookie Settings”, which allow you to easily designate how cookies and other Tracking Technologies on 313RED web pages may be used by your browser. 

Please note that disabling, rejecting or choosing to partially accept cookies or other Tracking Technologies may negatively impact your experience using our Services, as some features and services on our Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. 

Additional Cookie Information

How Long do Cookies and Web Beacons persist on my Browsing Device:

The length of time a cookie or web beacon will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.

First and Third Party Cookies:

• “First party cookies” are cookies that belong to us and that we place on your device. “Third-party cookies” are cookies that another party places on your browsing device when you visit our site.
• Third parties setting cookies from our website will be providing a service to us or a function of the site but we do not always control how third party cookies are used. You should check the third party’s website for more information about how they use cookies.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Online Services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
• Advertising cookies. These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations such as advertising partners. This means after you have been to our site you may see some advertisements about our services elsewhere on the internet.
• Social media cookies. In order to enhance your internet experience and to make the sharing of content easier, some of the pages on our website may contain tools or applications that are linked to third party social media service providers such as Facebook, Twitter or Google+. Through these tools or applications the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s website for further details about how they use cookies.

How to Manage Cookies from Our Websites

The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

C. Location and Movement Data Collection and Sharing in the 313RED App

As described in Section 2, we collect precise location data, driving event, and movement data from your device to provide the 313RED Services, and may share your personal information, including location and movement data, with other 313RED members in any FaithGuardian account you belong to, and with third parties for research, analytics, attribution, and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings. For more information on how to control these settings please see the following:

Disconnect Location Data and Movement Data in Device Settings. 
You may be able to turn off device location data collection through your mobile device settings. For example, depending on your mobile device, you may be able to “Turn location services ‘OFF,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the 313RED app to access device location data and you can also adjust your device settings to limit the app’s access to WiFi and Bluetooth information. Please note that your 313RED app may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.

If you no longer want to continue using the Products and/or Services, uninstalling the 313RED app (as applicable), removing the battery from or disabling the Products, and logging out from our Service will also stop us from collecting your location.

D. Web-Based Personal Information Sales

You may also exercise your Opt-In and Opt-Out rights related to web-based personal information sales or sharing via all of our websites, please click the “Do Not Sell or Share My Personal Information” link in the footer of the website and adjust the toggles as applicable.

Please note these settings must be completed for each browser on each device you use and for each of our websites (313.red) separately, and will not affect App-based settings. If you clear your cookies or your browser is set to do so, you will have to exercise the choice again.

VI. OUR POLICY TOWARDS CHILDREN

313RED takes special precautions to protect the privacy of our younger members. 313RED does not knowingly collect personal information from children who do not meet applicable minimum age requirements without verifiable consent of a parent or guardian, and our Services are only intended to be used by children with significant parental or guardian involvement and approval.  

If 313RED learns that we have inadvertently collected personal information of a child without parental consent as required by law, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child has a registered account with our Services or is using our Products without your consent, please alert us immediately by emailing privacy@313.red.

By enabling your child to create a member account and/or permitting your child to use the Products or Services, you expressly agree to the practices described in this Privacy Policy and you consent to the collection, use, and disclosure of your child’s personal information as described herein.

A. Setting up a Child Account

If a parent wishes to add a member who is a child to our Services, we request the parent provide verifiable consent, through one of several methods, such as by verifying the parent’s driver’s license during sign up, or by submitting a parental consent form (available here) via mail or email. The child will then be able to participate in most aspects of the 313RED Services. In some instances, our Products are intended to be worn and used by children and pets. By providing the Products to a child, you represent and warrant to 313RED that you consent to such child’s use of our Products and Services and further consent as a parent to enable and permit 313RED’s collection and use of the information from the Products and Services used by the child as stated in this Privacy Policy and the Terms of Service. 

B. Personal Information we Collect about Children

We take special precautions to collect only as much information as is reasonably necessary for the child to use our Products and Services.

C. Information sharing about Children

313RED may disclose a child’s personal information to our third-party vendors, Service Providers, and business partners as described in this Privacy Policy. We do not share or sell personal information of members we know to be children. Profile and location information for children using the Service may be shared with other members of any FaithGuardian account the child joins. Please note the child may exchange messages with those FaithGuardian members. You are responsible for monitoring your child’s account and location-sharing activity through our Products and Services and for blocking or permitting location-sharing features.

D. Contact Us Regarding your Child’s Account or Information

The parent or legal guardian has a right to request to review or have deleted the child’s personal information and may withdraw consent for our Products and Services to collect any further personal information from the child. Please contact us at privacy@313.red to request to review and/or delete any personal information we may have collected from the child, or to withdraw permission for 313RED to collect any additional information from the child. We will require the parent or guardian to provide us with sufficient identification before providing access to, or acting upon, such personal information.  

VII. HOW WE PROTECT YOUR INFORMATION

313RED cares about the security of your information. The actions we take to protect your personal information are described below.

A. Security 

We have implemented appropriate standards to reduce the risk of unauthorized or unlawful access of your personal information. No security system is impenetrable and we cannot absolutely guarantee the security of our systems and your information. 

We will never send you unsolicited messages or contact you by phone to request sensitive information, such as your account ID, password, payment, or national ID numbers. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to share any sensitive information through these means. 

If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify any impacted individuals and take steps in accordance with any applicable laws and regulations.

B. Accuracy and Confidentiality of Your Email Address and Password

You are responsible for the secrecy of your password and ensuring the email address associated with your account(s) is accurate. We use your email address to contact you about service updates, changes to our policies, and account activities such as requests for your information. We recommend using a strong password unique to this service. If you believe your account has been compromised, change your password immediately via the applicable app or website. 

313RED is not responsible for information or data transmitted to a third party as a result of a member providing an incorrect phone number or email address.

C. Fraud Prevention

To prevent the misuse of our Services by bots or other nefarious means, we use anti-bot services to ensure the integrity of our service.

D. Onward Transfer 

With respect to onward transfers to third-party agents acting on our behalf, 313RED remains responsible should its agents process information in a manner inconsistent with the Data Privacy Framework Principles or other applicable laws. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

E. Data Retention

313RED retains the information we receive as described in this Privacy Policy for as long as you use our Products or Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. The purposes for which we process information may dictate different retention periods for the same types of information. 

VIII. ADDITIONAL STATE, COUNTRY, AND REGION-SPECIFIC PRIVACY TERMS

A. California Consumer Privacy Act (CCPA) and California Consumer Rights Act (CPRA)

California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you have the right to request any or all of the following information relating to your personal information we have collected and used in the last 12 months, upon verification of your identity:

• provide you with the specific pieces of personal information we have collected about you and information about: the categories of personal information we have collected about you; the categories of sources of the personal information; the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; the categories of personal information we have sold or shared and the categories of third parties to whom the information was sold or shared; and the business or commercial purpose for collecting or selling/sharing the personal information.

You also have the following rights with regards to your personal information as further described in our Notice of Collection:

• the right to opt-out of personal information sales and shares for cross-context behavioral advertising; 
• the right to limit our use of your sensitive personal information;
• the right to correct inaccurate personal information about you;
• the right to delete certain information we have about you;
• the right for us to provide you with information about the financial incentives that we offer to you, if any; and
• the right to not receive discriminatory treatment for exercising these rights.

Certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide our Services to you; if you ask us to delete it, you will no longer be able to use our Services.

Categories of Personal Information Collected

Depending on your use of our Services, the following categories of personal information may have been collected in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act “CCPA” and the California Privacy Rights Act “CPRA”):

• Identifiers; such as a real name, user name, account name, account information, ID verification information, telephone number, email address, online identifiers, device identifiers, IP address, mobile device identifiers, shipping address;
• Purchase information; such as payment card number, payment account details, billing address, and other payment information;
• Characteristics of Protected Classifications under state or federal law; such as age, gender, ethnicity, and race;
• Commercial Information; such as products or services interaction, motion, and fitness information, and purchase history;
• Internet or Electronic Network Activity information; such as browsing history, search history, and information regarding interactions with our Products and Services, websites, mobile apps, and/or advertisements;
• Geolocation Information; such as location data derived from IP address or device settings;
• Inferences; such as consumer preferences drawn from the above.

California Consumer Information Sold or Shared in the Last 12-Months

In the previous 12 months, if you were a 313RED member we have sold or shared the following categories of personal information to third-party partners and advertising partners for targeted marketing, attribution, analytics, and research purposes (subject to your settings and opt-outs): Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

Other Ways to Exercise Your California Rights

Alternatively, you may submit a request to exercise your California privacy rights via email by contacting us at privacy@313.red and including your account name and mobile telephone number as well as the consumer right you would like to exercise. To protect your privacy and security, we take reasonable steps such as verifying your email address and specific information to verify your identity and request. For faster response times, we recommend members submit all requests through the in-App Privacy & Security Settings.

B. Legal Basis for Processing

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it as well as our records of your country of residence. Depending on where you reside, we may rely on different legal bases to process your information.

C. California’s “Shine the Light” Law 

California's "Shine the Light" law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the “Do Not Sell My Personal Information” link available in the in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.

D. Your Nevada Privacy Rights

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt-out of future sales of certain covered information that a website operator has collected or will collect about the resident. To exercise your Nevada opt-out rights: you may click on the "Do Not Sell My Personal Information" link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle. Alternately, you may send an email to privacy@313.red with the subject line “Nevada Privacy Rights” and include your account name and mobile telephone number. We may need to contact you to request additional information to verify your request. For faster response times, we recommend members submit all requests through the in-App Privacy & Security Settings.

E. International Transfer

You agree that all information collected via or by 313RED may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the United Kingdom, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to 313RED, you explicitly consent to the storage of your information in these locations, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

IX. LINKS TO OTHER WEBSITES AND SERVICES

Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. Please remember that when you use a link to go from the 313RED to another website or app, or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction, on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies, and 313RED is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein. 

X. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, so please review it frequently. If we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted. 

If you object to any of the changes to this Privacy Policy, you must cease using our Products and/or Services, and may request us to erase your personal information. Any information that is collected through your use of our Products or Services is covered by the Privacy Policy in effect at the time such information is collected.

XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at privacy@313.red or by postal mail:

313RED LLC

ATTN: Privacy

700 S. Rosemary Ave, Suite 204

West Palm Beach, FL 33401

United States