Effective on: May 25, 2018

Last updated on: April 22, 2021

OUR CONTACT INFORMATION

Future Today Inc.

Address:  3723 Haven Ave Ste 133, Menlo Park, CA 94025

Phone number: 1 888 575 7564

Email address: privacy@futuretodayinc.com

Future Today Inc. (“Future Today”, “we”, “us”, “our”) takes the protection of personal data (“Personal Data”) very seriously. Future Today operates websites, mobile applications, OTT applications, and Connected TV applications (collectively, the “Service”). Please read this privacy policy (the “Policy”) to learn what we are doing with your Personal Data, how we protect it, and what privacy rights you may have under applicable data protection and privacy laws, such as the European Union General Data Protection Regulation, the United Kingdom General Data Protection Regulation (together, “GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Rights Privacy Act (“CPRA”).

What Is Covered by this Privacy Policy?

This Policy addresses Personal Data (which relates to both individuals and households) that we:

• Receive directly through our Service.
• Receive from individuals that contact us.
• Receive from our business partners, including content partners.
• Process to promote our products and services.

What Is Not Covered by this Privacy Notice?

Human Resources Personal Data

This Notice does not apply to the Personal Data of employees, job applicants, contractors, business owners, directors, officers, and medical staff of Future Today.

Information Which Does Not Constitute Personal Data

If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered Personal Data and this Policy will not apply to our processing of that information.

This Policy tells you, among other things:

• What Personal Data we collect about you and how we obtain it
• The legal bases for processing your Personal Data
• For what purposes we use that Personal Data
• How long we keep your Personal Data
• With whom we share your Personal Data
• Your rights with regard to the Personal Data we collect about you and how can you exercise those rights
• How we protect your Personal Data
• How to contact us

Within the scope of this Policy, Future Today acts as a data controller or “business” for the Personal Data we process. This means that we decide how and why Personal Data is collected and further processed.

The GDPR and other applicable data protection laws require that we have a valid reason to use your Personal Data. This is called the “lawful basis for processing.” We may process your Personal Data:

• Because you gave your consent.
• Because we need to perform a contract with you.
• Because we have a legitimate interest in processing your Personal Data and it is not overridden by your rights. Some of those interests include:
  – Monetizing your use of the Service with ads which are relevant to you.
  – Enhancing, modifying, personalizing or otherwise improve our Service and communications for the benefits of our customers.
  – Identifying and preventing fraud.
  – Enhancing the security of our network and information systems.
  – Determining the success of our Service, promotional campaigns, and advertising.

• Because we need to comply with the law.
• On another ground, as required or permitted by law.

When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis and object to this processing. To do so, please use the contact details provided here.

Where we process your or your child’s Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

Where we receive your Personal Data as part of the provision of the Service to/from you or your brand to fulfil a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the Service to you or fulfill our contractual obligations with you.

You have specific rights regarding your Personal Data that we collect and process.

In this section, we first describe those rights and then we explain how you can exercise those rights.

This is also called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you (or your child), such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things.

This is also called the right of access. This right allows you to ask for full details of the Personal Data we hold on you, including confirmation of whether we process Personal Data concerning you (or your child), and, where that is the case, a copy or access to the Personal Data and certain related information.

Once we receive and confirm that the request came from you or your authorized agent, we will disclose to you:

• The categories of your Personal Data that we process
• The categories of sources for your Personal Data
• Our purposes for processing your Personal Data
• Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period
• The categories of third parties with whom we share your Personal Data
• If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you
• The specific pieces of Personal Data we process about you in an easily sharable format
• If we sold or disclosed your Personal Data for a business purpose, the categories of Personal Data and categories of recipients of that Personal Data for both sale and disclosure
• If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests
• The appropriate safeguards used to transfer Personal Data from the EEA or the UK to a third country, if applicable

Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.

This is also called the right to rectification. This right entitles you to ask us to correct without undue delay anything that you think is wrong with the Personal Data we have on file about you (or your child), and to complete any incomplete Personal Data.

This is called the right to erasure, right to deletion, or the right to be forgotten. This right means you can ask for your Personal Data to be deleted.

Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.

This is called the right to object. This is your right to tell us to indefinitely stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party) as the lawful basis for processing your Personal Data. You may also object at any time to the processing of your Personal Data for direct marketing purposes.

We will stop processing the relevant Personal Data unless:

• we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or

• we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

This is called the right to data portability. It is the right to ask for and receive a portable copy of your Personal Data that you have given us or that we have observed from your use of our services, so that you can:

• Move it;
• Copy it;
• Keep it for yourself.; and/or
• Transfer it to another organization.

The right to data portability only applies when:

• our lawful basis for processing this information is consent or for the performance of a contract; and
• we are carrying out the processing by automated means.

Please note that the right does not cover any data that we may have created based on the data you have provided to us.

When this right applies to you and it is technically feasible, we will provide your Personal Data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you a copy in electronic format.

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.

If you have given consent for your details to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party to change your preferences.

We will not discriminate against you for exercising any of your privacy rights. Unless the applicable data protection or privacy laws permit it, we will not:

• deny you the Service.
• charge you different prices or rates for the Service including through granting discounts or other benefits or imposing penalties.
• provide you a different level or quality of the Service.
• suggest that you may receive a different price or rate for the Service or a different level or quality of the Service.

Our disclosure of non-personally identifiable information such as your device and advertising identifiers may qualify as sales of Personal Data under certain data protection and privacy laws.

Some of those laws give you the right to ask us to not sell your Personal Data at any time, referred to as the right to opt out. To exercise the right to opt-out, you may alter your settings in the in your device as explained in this section. If your device does not offer options to limit ad tracking, contact us as we explain here.

Please consider that when you change your device tracking preferences to limit ad tracking or we handle the request for you you will receive the same number of ads, but they will be less relevant to you.

Once you make an opt-out request, we will not ask you to reauthorize sale of your Personal Data for at least twelve months. However, if you change your mind, you may opt back into Personal Data sales at any time by changing your preferences in the Future Today Privacy Center within the Service. will only use Personal Data you provide us in an opt-out request to review and comply with the request.

If you have directed us not to sell your Personal Data, you can opt into the sale of your Personal Data at any time by changing your ad-tracking preferences in your smart device as we explain here. If your device does not offer options to enable again ad tracking, contact us as we explain here.

In addition, we do not knowingly sell the Personal Data of individuals that we know are less than sixteen (16) years old.

To exercise any of the rights described above, or to get assistance to exercise those rights, please use the contact details available in the Contact Us section and provide us with your email address (so we can contact you about your request) and your device ID (Don’t know how to find it?) if your requests relates to the Personal Data we may process in the context of our Service.

Please email us at privacy@futuretodayinc.com and we will get back to you within 1 business day

To correctly respond to your privacy rights requests (except requests to stop the sale of your Personal Data), we need to confirm that YOU made the request. Consequently, we may require additional information to confirm that you are who you say you are.

We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with Future Today and confirm with us that they gave you permission to submit this request.

We will confirm the receipt of your request within ten (10) business days, and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to thirty (30) calendar days to reply to your requests (except requests to stop selling your Personal Data) from the day we received your request. If we need more time (up to ninety (90) days in total), we will inform you of the reason why and the extension period in writing.

If your request is covered by the CCPA, consider that we will only cover the twelve-month period preceding the moment we receive your request in any disclosures we provide you with.

We will act upon your request to opt out from the sale of your Personal Data within fifteen (15) business days. We will also notify the third parties to whom we sold your Personal Data of your request and instruct them not to further sell your Personal Data. We will inform you about this in ninety (90) calendar days from the receipt of your request.

If we cannot satisfy a request, we will explain why in our response. For data portability requests, we will choose a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without difficulty.

We will not charge a fee for processing or responding to your requests. However, we may charge a fee if we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

If the GDPR applies to our processing of your Personal Data, you have the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data.

Specifically, you can lodge a complaint in the Member State of your habitual residence, place of work, or the alleged violation of the GDPR.

Protecting the privacy of young children is especially important to us. We do not knowingly collect Personal Data that can directly identify anyone under the age of sixteen (16).

If you are a parent or guardian and you are aware that your child has provided us with personally identifiable information, please contact us. If we become aware that we have collected personally identifiable information from children without verification of parental consent, we take steps to remove that information from our servers. Viewers under the age of 16 must use the Future Today Inc. sites under adult supervision.

Future Today adheres to the U.S. Children’s Online Privacy Protection Act of 1998 (“COPPA”) and the guidelines of the Children’s Advertising Review Unit (“CARU”) of the Council of Better Business Bureaus, Inc. in the parts of our Service directed to children under the age of thirteen (13). Please help us protect your children’s privacy by instructing them never to provide personal information (like their full name, e-mail address, home address, telephone number, etc.) without your permission.

We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction.

If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Last updated” date. By continuing to use our Service after we post any of these changes, you accept the modified Policy.

If you have any questions about this or our processing of your Personal Data, or want to submit a privacy rights request, please write an email at privacy@futuretodayinc.com or call at 1 888 575 7564 or by postal mail at:

Future Today Inc.

3723 Haven Ave Ste 133, Menlo Park, CA 94025

If you are submitting a privacy rights request, include the information we mention in this Section of the Policy to enable us to locate you in our systems.