Social Cash, Inc. (DBA Fabric Foundation Inc)

LAST REVISED ON OCTOBER 16, 2020

I. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes the types of personal information that Social Cash, Inc. (“us,” “we” or “our”), collects through this website (the “Site”) and the associated services we provide (collectively with the Site, the “Services”), and how we collect, use, and share that information. This Privacy Policy does not govern our collection of personal information through any website or other means, other than through the Services.

The purpose of this Privacy Policy is to provide to users and potential users of our Services information about the nature, scope, and purpose of the information we collect, use and process and to advise users of their rights. We have implemented numerous technical and organizational measures to protect information we possess. By using the Services, you accept our practices surrounding the collection, use, and sharing of information provided by you in the manner described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you cannot access, browse, or use the Services.

The Services are provided for the benefit of users in the United States only. Although non-United States persons may visit the Site, they will not be able to become registered users of our Services, including the Token Sale Activities defined and described in Section II below. For certain provisions applicable to users in the State of California, see Section XIII below.

II. PERSONAL DATA WE MAY COLLECT

A. Information You Give Us

Except for physical location information and tracking technologies (as described in Section II.B), you do not have to give us any personal information to browse the Site. However, if you want to purchase pre-sale rights for our Security Tokens, register for our Security Token Sale, and/or participate in our Security Token Sale (collectively, the “Token Sale Activities”) you will be asked to provide personal information either directly to us or to the third party or parties we have engaged to assist with the Token Sale Activities, including know-your-customer, anti-money laundering and accreditation compliance (references to “us” below includes such third parties). Once you provide us with personal information, you are no longer anonymous to us. This information may include:

• Your name;
• Your email;
• Proof of address;
• Proof of identity (passport, id card, driver license details);
• Your date of birth;
• Numbers that you may use or have registered with your local tax authority;
• Photographs of you;
• Confirmation of proceeds sources; and
• Sworn statements.

You should only provide the above-mentioned information and details upon our direct request to you as specified in respective email or messages from us.

We reserve right to request the basic personal information described above (the “Personal Data”) prior to completing any Token Sale Activities.

We may refuse you access to the Services if we have reasonable doubts as to validity, authenticity, or genuineness of the Personal Data.

If you do not provide us with the Personal Data, you may not be able to use the full functionality of the Services or participate in any of our Token Sale Activities.

B. Location Information

In order to access and use certain areas or features of the Services, you consent to our collection and use of your physical location information if you use the Services on a location-enabled device (including GPS, cellular, or Wi-Fi networks) or from your browser in order to verify your eligibility to participate in the Services or our Token Sale Activities.

In addition, you consent to our collection and use of certain information about your use of the Services through the use of tracking technologies or by other passive means. We may use analytics applications such as Google Analytics to help collect and analyze this information. This information generally includes, but is not limited to, the domain name of the website that led you to the Site, search engines used, your internet protocol (IP) address, the length of time spent on the Site, the pages you saw on the Site, other websites you visited before and after visiting this Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics. 

The following section provides additional detail on our collection and use of this information.

• Log information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.

• Links. The Site may include links in a format that enables us to track  whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.

• Uniform Resource Locators (“URLs”). When you visit or access this Site, we automatically receive the URL of the site from which you came and the site to which you go when you leave this Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on this Site.

• Cookies. When you access this Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identify your browser. We use cookies to improve the quality of this Site by storing user preferences and tracking user trends. Most web browsers accept cookies automatically, but can be configured to not do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some or all of the features available through the Services.

• Web Beacons. Web beacons (also known as ‘pixel tags’ or ‘clear GIFs’) are 1×1 single-pixel graphics that allow us to count the number of users who have visited the Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of Site users, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for Site visitors. We may also include web beacons in HTML-formatted email messages that we send to determine which email messages were opened.

III. HOW WE USE PERSONAL DATA

We comply with our obligations under applicable law by keeping Personal Data up to date where needed based on the purposes for which the Personal Data is being processed; not collecting or retaining excessive amounts of data; establishing appropriate technical measures to protect Personal Data from loss, alteration, misuse, unauthorized access, and disclosure as it is transmitted, stored, or otherwise processed; and using appropriate measures to securely destroy Personal Data when we no longer need or are required to maintain it.

We may use Personal Data collected through the Services for purposes of:

• Managing your account;
• Administering our Site and the Services;
• Processing your eligibility to participating in any of our Services, including Token Sale Activities;
• If you are eligible, processing your purchase of pre-sale rights to our Tokens, registration for our Token Sale or participation in our Token Sale;
• Responding to your questions and feedback;
• Contacting you, by email, postal mail, or telephone with information about the Services and our Tokens;
• For such purposes as you may authorize at the time you submit the information;
• Auditing, research, and analysis to maintain, protect, and improve this Site and our Services;
• Ensuring the technical functions and security of our network; or
• Improving and customizing the content and layout of the Site.

IV. PERSONAL INFORMATION WE SHARE

We do not sell, rent, trade, or otherwise share Personal Data collected through the Site, except as described below:

• Subsidiaries and Agents. We may share Personal Data with our subsidiaries and agents including our broker-dealer as reasonably necessary for purposes of determining your eligibility for any of our Token Sale Activities or other Services.

• Service Providers. We work with third parties that provide various services to us. Such services may include, but are not limited to, broker-dealer activities, website hosting, compliance, marketing, website usage analytics, and order fulfillment service providers. We may share Personal Data and non-personal information with these third parties for the purpose of enabling us to provide the Services to you. We do not bear any responsibility for any actions or policies of such third parties.

• Consent. We may share Personal Data with third parties in accordance with any consent you provide.  The processing and use of that Personal Data with such parties will take place in accordance with their privacy policies and terms of use.  We encourage you to review those policies and terms carefully.  We will not be liable for any use of your Personal Data in violation of those policies and terms.

• As Required by Law. We may disclose Personal Data or any information collected through this Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of improper activity.

• Corporate Purposes. We may provide Personal Data to a third party in connection with a potential transaction (e.g., acquisition or other corporate combination) with that third party, including any authorized agents of ourselves or of such third party.  Any such third party will be subject to confidentiality and nondisclosure obligations no less restrictive than the provisions of this Privacy Policy.

V. AGGREGATE INFORMATION

We may compile de-identified Personal Data and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site or Services, demographic information about users of the Site, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Policy, and for any other lawful purpose.

VI. YOUR CHOICES

A. Information You Provide

You can always choose whether or not to provide information on the Site or the Services. However, if you choose not to disclose certain information, you may not be able to register as a user of the Site or Services, which may also limit your access to certain portions of the Site.

B. Communications From Us

If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at [email protected].  If you are a registered user of the Services, you cannot opt out of required system messages regarding the Services or your account.

C. Do Not Track

As described in more detail in Section II.B of this Privacy Policy, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.

D. Your Rights and Your Personal Data

You have the following rights with respect to your Personal Data:

• The right to request a copy of your Personal Data which we hold about you;
• The right to request that we correct any Personal Data if it is found to be inaccurate or out of date;
• The right to request the deletion of your Personal Data when it is no longer necessary for us to retain such data;
• The right to withdraw your consent to the processing at any time of Personal Data to which you provided consent for processing;
• The right to request that we provide you with your Personal Data and where possible, to transmit that data directly to another data controller (known as the right to data portability);
• The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing;
• The right to object to the processing of Personal Data (where applicable); and
• The right to lodge a complaint with a data supervisory authority.

E. Transfer of Data Abroad

We will transfer Personal Data abroad only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If we transfer Personal Data to a foreign third party acting as our agent, we will also require the third party to have adequate privacy protections in place.

F. Further Processing

If we wish to use your Personal Data for a new purpose not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing that use and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

VII. INFORMATION STORAGE AND SECURITY

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of Personal Data provided on or through the Services. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect Personal Data about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that Personal Data is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII. A SPECIAL NOTE ABOUT CHILDREN

Children are not eligible to use the Site or the Services, and we ask that minors (children under the age of 18) not submit any Personal Data to us.

IX. EXTERNAL LINKS

The Site or the Services may contain links to various websites that we do not control. When you click on one of these links, you will no longer be transacting business through the Site or the Services. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Site. If you visit a website that is linked to the Site or the Services, you should consult that website’s privacy policy before providing any Personal Data. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

X. OPERATIONAL CONTROL

We control and operate the Site and Services from the United States. We may limit the Site’s and Services’ availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

XI. UPDATING INFORMATION

You may change Personal Data that you have provided about you by contacting us at: [email protected].

XII. UPDATES TO THIS PRIVACY POLICY

We may change or update this Site or any of our policies and procedures without prior notice. We will post a notice on this Site to advise you of any significant changes to this Privacy Policy and indicate via the ‘Last Updated’ legend at the bottom of this Privacy Policy when it was most recently updated.

XIII. CALIFORNIA RESIDENTS

If you are a California resident, this section provides additional information on our use of "personal information" (as defined in the California Consumer Privacy Act ("CCPA").

A. Categories of Personal Information We Collect

Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.” 

The categories we collect include:

• Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
• Commercial information (such as transaction data);
• Financial data (such as credit card information);
• Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
• Geolocation data (at an IP-based or city/state/zip level);
• Inference data about you drawn from the data in this section (based on user profile information);
• Legally protected classifications (such as age and gender);
• Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Services, such as additional profile information or user-generated content).

B. The Sources From Which the Categories of Personal Information Are Collected

We collect Personal Data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements.

C. Business Purposes for Our Collection of Personal Information

The following is a list of the business purposes for our collection of information.

• Complete a purchase or provide the Services you have requested, including invoicing and accounting;
• Respond to your request for information and provide you with more effective and efficient customer service;
• Provide you with updates and information about the Services;
• Contact you by email, postal mail, or phone regarding our Services and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
• Customize the advertising and content you see on the Services;
• Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
• Secure our websites and applications, and resolve technical issues being reported;
• Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

D. Sharing of Categories of Personal Information

We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.

E. CCPA Rights Disclosure

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
• Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this State-Specific Notice and our Privacy Policy);
• Provide you with the specific pieces of personal information we collect about you; and
• Delete personal information we have about you

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.

To make a CCPA request, please contact us at [email protected]. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.

The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.

If you would like further information regarding your legal rights under California law, please contact us at [email protected].

F. California Do Not Sell Notice

If you are a California resident, the CCPA provides you with the right to opt out of the "sale" of your "personal information." We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a "sale" under the CCPA. If you want to opt out of these activities, please contact us at [email protected]. Please note that some or all of the Services may not function if you choose to opt out of such activities.

XIV. QUESTIONS REGARDING THIS PRIVACY POLICY

If you have any questions or comments regarding this Privacy Policy, please contact us at: [email protected].

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This Privacy Policy is effective as of October 16, 2020.