Last Updated: October 12, 2021

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1. Introduction

This Privacy Policy describes what information Fortress Digital Technologies, Inc. (“Fortress,” “we,” “our,” or “us”) may collect and how we may use such information when you visit or use the Fortress and Fortress Kids mobile applications (collectively, “Fortress Applications”) or our website at www.usefortress.com (the “Site”). The Fortress Applications and Site are collectively referred to herein as the “Services.”

 

1.1 Our Services

Our Site provides information about Fortress, the Fortress Applications and blogs and information on topics including but not limited to parenting, technology, and childhood development.

 

The Fortress Applications currently have the Fortress Chat, a cloud-based mobile messaging application. In addition to creating your own account, you can also add Child Accounts and invite your contacts to join. Fortress automatically deploys the configuration and the instructions given by you and you are solely responsible for the configuration of the Services for your Child Account(s).

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In the future, we will have (a) Fortress App Management which allows you to monitor the applications on mobile devices under your control for your Child Accounts, and (b) Fortress Browser which allows you to whitelist the websites your Child Account(s) can access.

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1.2. Terms of Service

This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available at www.usefrotress.com/terms. This Privacy Policy should therefore be read in conjunction with those terms.

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1.3. Table of Contents

This Privacy Policy explains the following:

• your consent when you use our Services

• the legal basis for processing your personal data;

• what personal data we may collect from you;

• how we keep your personal data safe;

• what we may use your personal data for;

• who your personal data may be shared with; and

• your rights regarding your personal data.

 

2. Consent and Children’s Privacy

2.1 Consent

By using the Services, you accept and consent to the collection, use, and sharing of the information on your account and, if applicable, on your Child Account(s) by Fortress in accordance with this Privacy Policy and consent to the Terms of Services, which are incorporated herein by reference. You also consent to the processing of all personal data stated in this Privacy Policy by the third party technological services listed here. 

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For users in the United States, the term “children,” as used herein, refers to minors under the age of 13. For users outside of the United States, “children” refers to those under the age of digital majority. 

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We process personal data on your and your Child Account(s) on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your fundamental rights and freedoms that require protections of personal data. 

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Your consent to personal data collection and processing may be revoked, without retroactive effects, in accordance with applicable law.

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2.2.  Child Accounts and Privacy

We do not allow any third-party advertisements on the Fortress Kids application.  We do not provide Personal Information of your Child Account(s) to any networks for use outside of the Fortress Services or send any kind of advertising communications to children.

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By creating your Child Account(s), you expressly and unequivocally (1) acknowledge that you are solely responsible for the management of those Child Account(s) including but not limited to the username(s), password(s) and other personal data, (2) consent to the collection and processing of information on these accounts in accordance with this Privacy Policy and on your behalf.

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The Services are designed to be a tool for parents and others to use to facilitate safe online interactions for children under their custody. While our Services include the collection of the information in accordance with this Privacy Policy and analysis of online interactions by children, we do not knowingly collect data from children under the age of 13 without first receiving verified consent.

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3. What Personal Data We Use

3.1. Basic Account Data

You provide your mobile number(s) and basic account data (which may include username, date of birth, first and last name, profile picture and e-mail and password) to create your Fortress account and any Child Account(s) that you choose to create. To maintain a trusting community on Fortress, we require that you provide your real name.

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3.2. Contact Information

When you add contacts to your account and your Child Account(s), we will collect the following personal data of your contacts: name, phone number and/or email address (if applicable), connection type (whether the contact is a member of your household member or village), and the designated access level to communicate with your Child Account(s). This data is required for the Fortress Chat feature to work.

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3.3. Your Messages

The Fortress Chat feature is a cloud-based messaging service. We store messages, photos, videos and documents from cloud chats on your account and your Child Account(s) on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. 
 

3.4. Phone Number and Contacts

We ask your permission to sync your contacts in order to make adding and inviting contacts to your Fortress Chat faster and easier. You can opt to add each contact manually as well as manually entering individual phone numbers or Fortress usernames. 

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You can always stop syncing contacts or delete them from our servers in Settings > Privacy & Security > Data Settings.
 

3.5. Location Data

Fortress Applications do not currently collect location information.
 

3.6. Cookies

The only cookies we use are those to operate and provide our Services on the Site. We do not use cookies for profiling or advertising. Your browser should allow you to control these cookies, including whether or not to accept them and how to remove them. You may choose to block cookies with your web browser.

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3.7 Usage And Log Information.

We may collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services; the features you use like our messaging, calling, groups (including group name), your interactions with our promotions and ads, and usage information like whether you are online, when you last used our Services (your "last seen").

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3.8 Device And Connection Information. 

We may collect device and connection-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, battery level, signal strength, app version, browser information, mobile network, connection information (including phone number, mobile operator or ISP), language and time zone, IP address, and device operations information.

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4. Keeping Your Personal Data Safe

4.1. Storing Data

We use third party technological services for the provision of Services, whose providers may process Registration Data and User Data collected in the course of providing us their services indicated below, as sub-processors. You authorize us to subcontract the services and the corresponding transfer of user data to the entities and countries listed here. 

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4.2. Retention

Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services. All message history is stored for up to 18 months, after which your message history will be deleted from our servers.
 

5. Processing and Using Your Personal Data

5.1. Our Services

Fortress is a cloud messaging service and device management platform. We will process your data to deliver your cloud chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage. 

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We also send alerts about the activities on your Child Account(s) to you and your Second Parent Account, if you have one.
 

5.2. Safety and Security

When you use the Fortress Services, your Personal Information is securely encrypted in transit and at rest. We have also put in place security measures and access control mechanisms to ensure that your information is prevented from loss and only accessed in an authorized manner.

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We store and process information by using the latest industry-standard techniques. However, we cannot guarantee or warrant that such techniques will provide complete security of your Personal Information.  Any transmission is at your own risk.

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Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

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5.3. Cross-Device Functionality

We may also store some aggregated metadata to create Fortress features that work across all your devices.

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5.4. Ads

We do not place ads on the Fortress Child app or send any kind of commercial promotional communications to children. 

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To deliver relevant, high-quality promotions and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, we may employ your usage and log information. We do not use or analyze any of your chat content for advertising or promotion. The only reason we store your messages is so your can access them from any of your devices (see Section 3.3)

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6. Who Your Personal Data May Be Shared With

6.1. Other Fortress Users

By entering into the Terms of Service and choosing to communicate with other users of Fortress, you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy.  You share your information (including messages) as you use and choose to communicate with other Fortress users through our Services. Your name, the username you choose, and your profile picture on Fortress will be visible to anyone using our service. We employ all appropriate technical and organizational measures to ensure a level of security for your personal data that is appropriate to the risk.
 
6.2. Third-Party Service Providers. 
We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. We work with these companies to support our Services, such as to provide technical infrastructure, delivery and other systems; market our Services; conduct surveys and research for us; protect the safety, security and integrity of users and others; and assist with customer service. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms.
We will not sell or rent your personal data to third parties. 
 

6.3 Second Parent Users.
When you add another user of Fortress to be a Second Parent, you are instructing us to give that user the same level of access to view and manage your Child Account(s) as you do. 
 

7. Your Rights Regarding the Personal Data You Provide to Us

7.1. Your Rights

Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data.

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7.2. Exercising Your Rights

If you wish to exercise any of these rights, kindly contact us using the details in Section 12 below.
 

8. Deleting data

8.1. Accounts

If you would like to delete your account, you can do this by contacting us using the details in Section 12. Deleting your account removes all messages, media, contacts and every other piece of data you store in the Fortress cloud. This action cannot be undone.
 

8.2. Messages

Deleting a message will delete it from your message history. This means that a copy will stay on the server as part of your partner's message history. In the one-on-one chat as soon as your partner deletes it too, it's gone forever. 

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In the Child App, message deletion is not allowed. This ensures that Parents will have full transparency of  the chat history of their Child Account(s). This means that if you send a message to a Child Account, although you may have deleted the message from your history, that message remains in the Child Account history. This also means that Household Chat messages will not be able to be deleted. 

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8.3 Account Self-Destruction

By default, if you stop using Fortress and do not come online for at least 12 months, your account will be deleted along with all messages, media, contacts and every other piece of data you store in the Fortress cloud.

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9 Changes to this Privacy Policy.

We will review and may update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page www.usefortress.com/privacy. Please check our website frequently to see any updates or changes to our Privacy Policy.

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10. Your California Privacy Rights. 

California residents are permitted by California law to request information about the manner in which we share certain categories of information with others for their marketing purposes. Please contact us using the details in Section 12  to request this disclosure.

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11. Links to Other Sites. 

We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

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12. Questions and concerns

If you have any questions about privacy and our data policies, please contact us at privacy@usefortress.com.

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