Effective date: December 3, 2024
This Privacy Policy tells you how we collect, use and share information we collect (a)
through the provision of our Services, and (b) on the CASSA website at
familydefender.wpenginepowered.com (the “Site”) or the CASSA application (the “App”). By using
the Services and/or the Site or App and submitting information you agree to the terms of
this Privacy Policy. This Privacy Policy should be read in conjunction with, and is
incorporated into, the Family Defender Technologies Terms and Conditions of Use.
This Privacy Policy is governed by the laws of the state specified in the Terms of
Service applicable to your Services. Capitalized, but undefined terms used in this
Privacy Policy have the meaning assigned to those terms in the Terms of Service
applicable to the CASSA Services you are using.
- The Services.
Family Defender Technologies LLC (“CASSA” or “we” or “us”), is a Georgia
corporation D.B.A. CASSA with an address at 3930 Ivy Lawn Ct, Buford, GA 30519. Our Services provide advice on the best methods to ensure your children stay safe and happy online. This policy applies to websites, apps, events and other services we operate under the CASSA name. - Data Collection by Family Defender Technologies.
The Account Data, Usage Data and personal data about you or your Accounts
(hereinafter the “Data”) that can be collected by us through the use of the
Services or the Site are as follows:- Browsing.
We may collect information when you visit the Site including
your device’s IP address, browser and operating system, and statistics
about how you use the Site. If you connect to our Site using a mobile
device we may also collect information about your device including the
operating system and browser used and a unique device identification
number. We may collect information from the online interactions of
subscribers through other websites, such as social media sites, email
accounts or other interactive sites when you identify those sites to us. - Account Data.
On registering for CASSA Services, we will collect the
following personal data: name, company/institution (if applicable to
Services chosen), email address, phone number, date of birth, payment
information (if applicable) and at least one user name and password (“Registration Data”). This data is obligatory and if it is not provided, an account cannot be created. - Profile Data.
When you complete your profile, you may also share additional details about you and your child, such as gender, interests, personality, school and social life, approximate location, etc. Some of this data may be considered sensitive or special in certain countries, such as details about health, racial or ethnic origins, religious beliefs or political affiliations. If you choose to provide this data, you consent to us using it as laid out in this Privacy Policy. - Content.
When you use our community service, you may post text and other types of content, such as your chats with other members. - Cookies.
We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember your purchase selections in your cart. These cookies usually are erased when you close your browser window. - Third Party cookies.
We may allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. For instance, we allow Google Analytics to place cookies through our Site to collect aggregated information about use of our Site and Site visitors to assist us in our analysis to provide better services to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties. - Marketing, Survey and Research Data.
If you submit any webform to us, we collect the data indicated in the forms indicated in and submitted through these forms by you, including name and email address. Required data in order to send the webform is indicated. This data is used for processing your request and contacting you for further communication. We also sometimes run (i) surveys, focus groups, or market studies for research purposes and (ii) promotions, events or contests for marketing purposes. When you choose to participate, you give us information to process your entry and participation, as well as your responses to our questions and your feedback. - Customer Support Data.
When you contact us, you provide us with information that may be necessary to help address your enquiry. Other people may also submit queries or reports involving you. Finally, our moderation tools and teams can collect additional data as part of their investigations.
- Browsing.
- How We Use Your Data
- Registration Data.
We are responsible for processing your Registration Data, which is used for communications with you and for the provision and management of your use of our Services. It is also used to measure and improve the Services and functionality and to provide customer service, send email notifications and (unless no longer in the distribution list) newsletters, or communications, in general, about the Services, products and novelties, and offers or promotions offered by us. We will use the Registration Data for these purposes and to comply with the Terms of Service applicable to your Services and other legal notices. - Data.
You and, if applicable, your registered Administrators and Users (collectively, your “Authorized Users”), will be sent notification emails, texts and other reports concerning certain Data monitored by the Services. Your Authorized Users will have access to all Data in our possession for review and, if necessary, correction. Your Authorized Users may request access to such Data by emailing our customer support at thefamily@familydefender.wpenginepowered.com. - Service.
We may do the following to improve our service and create new features and services: Run focus groups, market studies and surveys; Analyze how our service is used; Review interactions with customer care teams to improve service quality; Develop and improve new features and services, including through machine learning and other technologies, and testing them out; Conduct research and publishing research papers. - Sharing your Information.
We treat your Data with strict confidentiality in accordance with applicable law. However, we may reveal your Data or other information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas (provided that we will notify you of any such communication of your Data to the extent legally permissible), to enforce our Terms of Service or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others; (3) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Data may be one of the transferred assets); (4) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing customer service, processing orders, etc.); or (5) as otherwise described in this Privacy Policy. We will only share your Data with a third-party as described in items 3 through 6 of the preceding sentence if such third-party is obligated to protect your Data to the same extent we protect it under the terms of this Privacy Policy. We will never sell or rent your Data to third parties or augment, extend or combine your Data with data received from third party sources. Your Data will never be publicly displayed in any way by Family Defender Technologies or any person or entity acting on Family Defender Technologies’ behalf. - Commercial Communications.
By filling in and sending your Registration Data to us, you expressly consent to receive electronic commercial communications regarding the subject matter of the Services, and other services including alerts and notices about your Account(s), and, if you selected the “opt-in” mechanism, you may also receive newsletters, offers and promotions. If you do not wish to receive such information from us, you can expressly opt out by sending a notification to thefamily@familydefender.wpenginepowered.com.
- Registration Data.
- Children’s Privacy.
The Site and Services are designed to be a tool for parents and others to use to
facilitate safe and enjoyable online interactions for their respective Users. Only
those over the age of 18, or those with the valid consent of his/her parent or legal
guardian who is over the age of 18, may subscribe to our Services. Our Services
include analysis of a child’s personality, interests, and online interactions, but we
do not knowingly collect data from children under the age of 13 without first
receiving verified consent. If you are under 13 please do not submit any
information to us without parental consent. - Data Processing.
- User Data.
Upon your registration for, and deployment of, CASSA
Services, we collect Data from the information submitted by you and
authorized accounts associated with your Account(s), which may include
personal data relating to you, to your Accounts, you Users or to third
parties, including information about your devices used by Accounts,
websites and applications that your Accounts use, and contacts,
connections, messages and other communications, posted and received
by your Accounts and/or Users (collectively, “User Data”). In accordance
with applicable privacy law, to the extent that it applies to the Services,
you and your Users are the respective Data Controllers (or the
Responsible Party/ies) of this User Data and you appoint us as a Data
Processor of such User Data for the purpose of providing our Services.
For clarity, where the concepts of “Data Processor” and “Data Controller”
are not expressly contemplated by the applicable privacy laws, the parties’
obligations in connection therewith will be interpreted under those
applicable privacy laws to align as closely as possible with the scope of
those roles while still complying fully with those privacy laws. User Data is
not our property or under our control and is only monitored by us for
purposes of providing the Services if given approval by the User. Any User
Data that combines personally identifiable information with non-personally
identifiable information will be treated as personally identifiable
information. We will take reasonably appropriate steps to maintain the
accuracy of any User Data we collect. - Your use of User Data.
As Data Controller, you warrant that you have the
appropriate authority to collect and process the User Data and you agree
to (i) process and use the User Data in accordance with this Privacy
Policy, the applicable Terms of Service and applicable law (including any
laws in the country where you reside or make beneficial use of the
Service). You will not submit to the Services any personal data relating to
any individual that has not authorized such processing (unless you are
permitted to authorize such processing on that person’s behalf in
accordance with our Terms of Service and applicable law). You will protect
the confidentiality of any accessible User Data and prevent access by or
disclosure to any unauthorized third person. You will inform us within 24
hours about any problem arising in relation with management of your
Account(s) and/or User Data. You and your Users will be responsible for
any illegal use of other person’s data (personal or not) through the
Services, including any use contrary to applicable data protection laws and/or in violation this Privacy Policy (including the Federal Family Educational Rights and Privacy Act of 1974 (“FERPA”) and/or in violation this Privacy Policy. The parties acknowledge that (a) User Data may include personally identifiable information from education records that are subject to FERPA (“FERPA Records”); and (b) to the extent that User Data in our possession, custody or control includes FERPA Records, we will be considered a “School Official” (as that term is used in FERPA and its implementing regulations) and will comply with FERPA. We will not disclose FERPA Records as “Directory Information” under FERPA. - Data Processor Obligations.
To the extent that we are a Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any User Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to User Data only to those employees who need to know it to enable us to perform the Services; (c) only process the User Data as specified by this Privacy Policy and in accordance with your instructions, and (d) will not use the User Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the User Data and will destroy it. Other than as described in this Privacy Policy or the applicable Terms of Service, we will not disclose User Data to any third party without your prior written consent or pursuant to court or administrative order. - Subcontracting.
As Data Processor we may provide access to any User Data to a subcontractor processor if we reasonably consider such access and processing necessary to the performance of the Services. In the event of such access and by a subcontractor or any other third-party, before the access takes place, we shall ensure that an agreement with the third party is in place which is sufficient to require it to treat personal data in accordance with the applicable provisions of this Privacy Policy. In particular, you authorize us to subcontract to the third parties mentioned in the following section on international transfers. - Data removal.
We generally retain your User Data on an identifiable basis for 30 days, after which it is deleted. We may retain portions of your User Data indefinitely as needed for the purpose of providing reports to you concerning your Account(s). If you wish to remove all the User Data in your CASSA account, please uninstall CASSA from your devices, and send an email (as set out below), with a digital copy of your ID or other identification document to prove your identity. Once your identity is confirmed, we will immediately remove all of your Data from our active systems and back-ups within fifteen (15) days from confirmation of identity (except as indicated below). Each Account’s User Data is controlled by the Account and/or you as a Data Controller. We do not control any User Data and can not and will not provide access in response to any Account’s request to review or correct errors in his/her User Data, unless otherwise required by applicable law. We will forward any such requests received by us to you and you will be responsible for responding to any such requests. - Warranties.
You, as the party responsible for User Data that we process on your behalf as Data Processor for the provision of the Services, represent and warrant to us that:- You comply with all applicable laws with respect to the monitoring and control of devices and applications used by you or your Accounts; and
- You have all legally required informed consents from or on behalf of each and every data subject, including without limitation, each Account, whose personal data are submitted to us in the course of the provision of the Services or collected and transmitted to us by the Services.
- Indemnity.
You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of User Data and other third party personal data submitted to our systems during the course of your use and our provision of the Services.
- User Data.
- Data Security.
We have adopted technical and organizational measures to preserve and protect
your Data (including User Data) that we monitor from unauthorized use or access
and from being altered, lost or misused, taking into account the technological
state of art, the features of the information stored and the risks to which
information is exposed, including without limitation encryption of all Data at rest
and in transit. However, due to the nature of the information and related
technology, we cannot ensure or guarantee the security of your Data and
expressly disclaim any such obligation. If we learn of a security breach, then we
will attempt to notify you electronically as soon as reasonably possible (and
within any timeframes specified in our agreements with you, if applicable) so that
you can take appropriate steps. You have a role in the security of your information and you are responsible to make sure your log-in information is kept from other people. If your log-in information is lost or stolen, you can change your email/user name or password on the Account page of the App. If we receive instructions using your log-in information we will consider that you have authorized the instructions. - Analytics and other anonymous data use.
For the purpose of analyzing and improving our Services, we may anonymize
your Data and store and process this anonymized data. This anonymized data is
used only for our internal analysis to determine how our Services are used,
measuring their effectiveness, and providing general customer service. We may
share aggregated and anonymized information we collect with third parties,
including our service providers and affiliates, for the purpose of conducting
general business analysis. - Your Rights.
You have the right to access, rectify, erase, block and oppose any processing of
your personal data that we may have. You can update, amend or delete your
contact information at any time by visiting the Settings page on the App. You can
update or change your billing and payment information on the My Account page
on the App. You may also reach directly at thefamily@familydefender.wpenginepowered.com to
have your data rectified, erased, blocked, and oppose any processing of your
personal data that we may have.You can choose not to receive promotional
emails from us by “unsubscribing” using the instructions in any promotional email
you receive from us. This will not stop us from sending emails about your
account or your transactions with us. You can choose to delete or block cookies
by setting your browser to either reject all cookies or to allow cookies only from
selected sites. If you block cookies performance of the Site may be impaired and
certain features may not function at all. Moreover, you may at any time withdraw
your consent to the processing of your personal data and information. This
withdrawal will not have retroactive effects but may prevent us from providing the
Services. The above is without prejudice to applicable law enabling conservation
of your data for the purpose of defending our responsibility and complying with
mandatory legal obligations. The aforementioned rights may be exercised by
contacting us at thefamily@yourfamilydefender.com or by mailing us at Family
Defender Technologies LLC 3309 Ivy Lawn Ct Buford, GA 30519. We will assist
you in accordance with the functionalities of the Services and this Privacy Policy
to address any Account request with regard to the processing of their personal
data. - Consent.
By registering for the Services and creating an account, you declare to have read and accepted the terms of this Privacy Policy. Without prejudice to the generality of the foregoing, you expressly and unequivocally consent to:- the collection and processing of your Data (or the Data of any other person, including your User(s), on whose behalf or for whose benefit the Services are provided in relation to your agreement with us, as contemplated by the applicable Terms of Service) by us in accordance with the indicated purposes and this Privacy Policy;
- the collection and processing of User Data on your behalf, as indicated herein; and
- the processing of all personal data stated in this Privacy Policy outside the European Economic Area or Australia (particularly in the United States of America)
- Changes to the Privacy Policy.
As we grow and change we may amend this Privacy Policy. The Policy in effect at the time you use the Site or App governs how we may use your information. If we make material changes we will post the revised Policy and the revised effective date on this Site and App and inform you of the change upon your next use of the Services. Please check back here from time to time to review any changes. - How to Contact Us
If you have questions about this Privacy Policy, you can reach out to thefamily@familydefender.wpenginepowered.com