Privacy Policy

1. Introduction and Scope

787 Cloisters, Inc. (“Company,” “we,” “our,” or “us”) operates the Famia website and related services (collectively, the “Service,” “Famia” or the “Site”). This Privacy Policy explains the collection, use, disclosure, retention, and protection of your personal information when you access or use Famia.

This Privacy Policy (as amended from time to time, the “Privacy Policy”) discloses the privacy practices for the Company with regard to our website, regardless of whether accessed through a tablet, computer, mobile phone, or other application. This Privacy Policy applies to all visitors and users of Famia, whether you access the Service via a computer, mobile device, tablet, or any other means. By using the Service, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. For convenience, the words “you” and “your” as used in this Privacy Policy refer to all users of the Site, including, without limitation, anyone who accesses or visits the Site.

Famia values your privacy. This Privacy Policy details important information about the collection, use, disclosure, retention and protection of your personal information. Famia provides this notice about our practices to help you make an informed decision about whether to use or continue using the Site. By signing up for our waitlist or otherwise accessing the Site, you are accepting the terms of this Privacy Policy, and you are consenting to the collection, use, disclosure and retention of your personal information in accordance with the practices described in this policy.

We are committed to protecting your privacy and handling your personal information in a transparent, responsible manner. If you do not agree with the terms of this Privacy Policy, please do not access or use Famia.

This Privacy Policy may be revised periodically and this will be reflected by the “effective date” above. If we make any material changes in the way in which your personal information is collected, used or disclosed, then we will notify you through the Site or by email. You are advised to review this privacy policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page, and your continued use of the Site after we make changes is deemed to be acceptance of those changes. If you object to any of the changes to the privacy policy, then you can close your account by contacting us.

This Privacy Policy does not apply to third-party websites, applications, or services that may be linked to or integrated with Famia. Please review the privacy policies of those third parties before providing them with any personal information.

2. Categories of Information Collected

We collect information in several ways when you interact with Famia. The categories of information we collect include the following:

Personal Information You Provide

When you voluntarily interact with Famia, you may provide us with the following personal information:

• Email address (e.g., when signing up for our waitlist, registering, completing any form).
• ZIP code (e.g., when signing up for our waitlist, registering, completing any form).

Cookies and Tracking Technologies

The Company does not use cookies or tracking technologies.

Technical Data Automatically Collected

When you visit the Site, Vercel, our infrastructure and content delivery network (CDN) provider, automatically receives the following technical data as a result of site traffic:

• IP address
• Approximate location derived from IP address
• Browser and device information
• Request information and referrer
• Server logs

This data is collected automatically by Vercel as part of serving web traffic and is not directly collected by the Company through cookies or tracking technologies.

Vercel retains server logs in accordance with its standard data retention practices. For more information about how Vercel processes this data, please see Vercel’s Privacy Policy.

3. How Information Is Used and Legal Basis for Processing

Purposes of Use

We use the information we collect for the following purposes:

• To operate, maintain, and improve Famia and its features.
• To provide our Site and its contents to you.
• To provide customer support, including responding to your requests and contacting you about the requests.
• To provide you notices about your account (such as updates to this Privacy Policy, the Terms of Service, or for other customer service purposes).
• To contact you by email in order to offer you special promotions or poll your opinions through surveys or questionnaires.
• To contact you by email or through your account to notify you of major Site changes.
• To fulfill any other purposes for which you provide it.
• To enable Vercel to deliver and route web traffic to and from the Site.
• To maintain the security and performance of the Site.
• To detect and prevent abuse, unauthorized access, and other harmful activity.
• To troubleshoot and resolve technical issues affecting the Site.

We do not sell your personal information. We do share anonymous aggregate user data.

Legal Bases for Processing (EEA/UK Users)

If you are located in the European Economic Area or the United Kingdom, we process your personal information based on the following legal grounds:

• Consent: For marketing communications and other processing activities where we have obtained your explicit consent. You may withdraw your consent at any time.
• Performance of a Contract: Where processing is necessary to provide you with the Service or to take steps at your request prior to entering into a contract.
• Legitimate Interests: For analytics, product improvement, site delivery and performance, fraud and abuse prevention, security, troubleshooting, and other processing, including Vercel’s processing of technical data for site delivery and security, where our legitimate interests are not overridden by your data protection rights.
• Legal Obligation: Where processing is necessary for compliance with applicable laws, regulations, or legal processes. Where we rely on legitimate interests as a legal basis, we have assessed that such interests are not overridden by your data protection rights and freedoms.

CAN-SPAM Compliance

Every marketing or promotional email we send includes a clear and conspicuous unsubscribe mechanism. If you opt out of receiving marketing communications, we will honor your request within ten (10) business days. Please note that even after opting out, you may still receive administrative or transactional communications from us.

4. Disclosure to Third Parties and Service Providers

We may disclose your personal information to the following categories of recipients:

Infrastructure and Service Providers

We use the following infrastructure and service providers, each located in the United States, to operate the Site and process the limited information described in this Privacy Policy:

• Vercel: Our infrastructure and content delivery network (CDN) provider, deployed in the iad1 U.S. region. Vercel receives technical request data, including IP address, approximate location derived from IP address, browser and device information, request information and referrer, and server logs, as part of delivering Site traffic.
• Supabase: Our database provider, hosted in us-east-1. Supabase stores user-submitted data, limited to your email address and ZIP code.

Both providers are located in the United States. Vercel’s receipt and processing of technical data is for operational purposes only, including delivering, routing, and securing the Site, and is not for advertising or cross-context behavioral advertising.

(a) Legal Obligations, Requests and to Comply with State and Federal Laws

We may disclose personal information if such action is necessary to comply with a legal obligation, to comply with state and federal laws, or to respond to a court order, subpoena, or search warrant.

Famia also reserves the right to disclose personal information that the Company believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to protect the security or integrity of the Site, and to protect the vital interests, property, or personal safety of Famia, our users or others.

(b) Business Transfers

In connection with any merger, acquisition, sale of all or a portion of our assets, financing, bankruptcy, reorganization, or similar transaction, your personal information may be transferred to the acquiring entity or successor. In such event, we will provide notice to you via email and/or a prominent notice on Famia prior to such transfer, and the acquiring entity will be subject to this Privacy Policy with respect to the personal information transferred.

(c) With Your Consent

We may disclose your personal information to third parties when you direct us to do so or when you have otherwise provided your explicit consent.

No Sale of Personal Information

We do not sell or share personal information for cross-context behavioral advertising. Vercel’s receipt of technical data is for operational purposes only, including delivering and securing the Site, and does not constitute a sale or sharing of personal information. California residents may exercise applicable rights as described below.

5. Cookies and Tracking Technologies

We do not use cookies or tracking technologies. Google Fonts is loaded on the Site to display typefaces but does not set cookies. Loading fonts from Google’s servers may result in your browser sending your IP address to Google; Google’s use of this information is governed by Google’s Privacy Policy.

Do Not Track Signals

Famia does not currently respond to “Do Not Track” browser signals or similar mechanisms. We are committed to reviewing our position in accordance with any future industry standards or legal requirements regarding Do Not Track signals.

6. Data Security and Retention

Security Measures

Famia uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to the Site, and you do so at your own risk. Once we receive your information, Famia makes commercially reasonable efforts to ensure the security of your information. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If Famia learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Famia may post a notice on the Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a written notice of a security breach (or to withdraw your consent from receiving electronic notice), you should notify us using our feedback form.

Children’s Privacy

Protecting the privacy of children is important to Famia. For that reason, Famia does not knowingly collect or maintain personal information from persons under 18 years of age, and no part of the Site is directed to persons under 18. If you are under 18 years of age, then please do not use or access the Site at any time or in any manner. If Famia learns that personal information of persons under 18 years of age has been collected, then Famia will take the appropriate steps to delete this information.

Data Retention

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected.

When personal information is no longer needed for the purposes described above, we will securely delete or anonymize it in accordance with our data retention policies and applicable law.

7. User Rights and Choices

How You Can Contact Us

If you have any questions or complaints about the use or disclosure of your personal information, this privacy policy, or our privacy practices, please contact Famia by sending an email to privacy@famiabeauty.com.

(a) All Users

Regardless of your location, you have the following rights and choices with respect to your personal information:

• Access the personal information we hold about you.
• Request deletion of your personal information, subject to certain legal exceptions.
• Opt out of marketing communications at any time by using the unsubscribe link in any marketing email or by contacting us at privacy@famiabeauty.com.

Consistent with the CAN-SPAM Act, every commercial email we send contains a functioning unsubscribe mechanism. We will honor opt-out requests within ten (10) business days.

(b) California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following additional rights:

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected the information, the purposes for collection, and the categories of third parties with whom we have shared the information.
• Right to Delete: You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Opt Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising. Vercel’s receipt of technical data is for operational purposes only, including delivering and securing the Site. For more detail, see “No Sale of Personal Information” in Section 4 above.
• Right to Limit Use of Sensitive Personal Information: To the extent we process sensitive personal information, you have the right to limit our use of such information to purposes permitted by law.
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. You will not receive different pricing or quality of service as a result of exercising your rights.

Authorized Agents: You may designate an authorized agent to submit a request on your behalf. We may require verification that you authorized the agent to act on your behalf.

Verification: We may need to verify your identity before fulfilling your request. We will ask you to provide information that matches the information we have on file.

How to Exercise Your Rights: To submit a request, please contact us at privacy@famiabeauty.com with the subject line “California Privacy Rights.” We will respond to verified requests within forty-five (45) calendar days. If we require additional time, we will inform you of the reason and extension period (up to an additional 45 days) in writing.

If you have any questions about this section, please contact us at privacy@famiabeauty.com and indicate “State Rights” in the subject line.

(c) Residents of Other U.S. States

Residents of states with applicable consumer privacy laws (including, without limitation, Virginia, Colorado, Connecticut, and Texas) may have additional rights, including the right to access, correct, delete, and opt out of certain processing of personal information. To exercise these rights, please contact us at privacy@famiabeauty.com.

(d) Users Outside the United States

The Site is hosted and operated using service providers located in the United States. Vercel, our infrastructure and CDN provider, is deployed in the iad1 U.S. region, and Supabase, our database provider, is hosted in us-east-1. If you are accessing the Site from outside the United States, please be advised that the information you provide Famia may be transferred to, processed and stored in the United States, including by these providers. You acknowledge and understand that the data protection and other laws of the United States might not be as comprehensive as those in your country. Through your continued use of the Site (which is governed by U.S. law, this privacy policy, and our Terms of Service), you acknowledge and accept the transfer of your personal information to the United States.

8. Policy Updates and Versioning

We reserve the right to update or modify this Privacy Policy at any time in our sole discretion. Any changes will be effective upon posting the revised Privacy Policy on Famia, and we will update the “Effective Date” and “Version” number at the top of this document.

For material changes to this Privacy Policy, we will provide notice by posting a prominent notice on Famia and/or sending an email notification to registered users at least thirty (30) days before the changes take effect. We will clearly identify what has changed and provide you with the opportunity to review the revised policy before it becomes effective.

Your continued use of Famia after the posting of any changes to this Privacy Policy constitutes your acceptance of such changes. If you do not agree to the revised Privacy Policy, you must discontinue your use of Famia.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

9. Contact Information