Your privacy is important to Confide (“Confide,” “we,” “us,” “our”). Confide has created this Privacy Policy (“Privacy Policy”) to demonstrate the commitment to protecting your privacy and to explain the personal data Confide processes, how Confide processes it, and for what purposes. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
This Privacy Policy is organized as follows:
Confide is a mobile and desktop security software program utilized by individuals and businesses. Confide allows users to share confidential and sensitive information on mobile devices and computers for the purposes of protecting such information from others. Confide utilizes sophisticated encryption software in order to ensure that all information shared between users remains secure, thereby driving meaningful interactions, relationships and creating better outcomes for individuals, professionals and businesses.
Confide collects personal information about you as you use Confide, through your interactions with us. “Personal information” is any information that relates to an identifiable individual and may include name, address, email address, phone number, login information (account number, password), social media account information, or payment card number.
We collect the following personal information:
Your Messages on Confide
When you use our services to send and/or receive encrypted messages, we store your message(s) in encrypted form. We do not have access to your messages at any time. Similarly, we do not have the ability to decrypt or read your encrypted messages.
When “confidential” mode is selected as “on” by you, we delete all messages:
When “confidential” mode is selected as “off” by you, we delete all messages:
Confide uses the information collected to provide you with a positive experience. In particular, we use the information to:
We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose, and otherwise process such information for our own legitimate business purposes, including historical and statistical analysis and business planning, without restriction.
We may share your personal information with third parties for the purposes of operating our business, delivering, analyzing, improving, securing, and customizing our services, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.
We may share personal information in the following ways:
Access, Edit and Delete Your Information.
Device Permissions.Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full or partial functionality.
Uninstall. You can stop all information collection by the app by deactivating your account and then uninstalling the Confide app using the standard uninstall process for your device. If you uninstall the Confide app from your mobile device, the unique identifier associated with your device will continue to be stored by us. If you reinstall the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Email. If you receive a commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may contact us if you decide to opt-out from receiving commercial emails and any other promotional communications that we may send to you from time to time. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the services.
Notice to Nevada Users. Under Nevada law, Nevada residents may opt-out of the "sale" of certain "covered information" (as defined under Nevada law) collected by operators of websites or online services. We currently do not sell covered information, as "sale" is defined by Nevada law, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Nevada law, please contact us. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.
International Transfers. Our services are hosted in the United States. If you choose to use our services from outside the United States, with laws governing data collection and use that may differ from United States law, note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may transfer your data from the United States to other countries in connection with the storage and processing of data to operate our business. By using our services and providing personal information, you consent to such transfer, storage, and processing.
Marketing Opt-Outs. Some of the third party service providers we use to market our services and show our ads on other websites and mobile applications may participate in the Digital Advertising Alliance's (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising on the websites and mobile applications that you visit and use, including use of Cross-device Data for serving ads, visit www.aboutads.info/choices, and www.aboutads.info/appchoice for information on the DAA's opt-out program specifically for mobile applications (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see www.networkadvertising.org/choices.
Should you allow notifications within the Confide mobile application, we may send you offers and promotions related to Confide. You may opt-out of these through the settings menu on your device.
Confide uses automatic data collection tools, such as cookies. These tools collect certain standard information that your browser sends to us (eg, Internet Protocol (IP) address, MAC address, clickstream behavior and telemetry). These tools help make your use of our services easier, more efficient, and personalized.
In addition to cookies, such other technologies may include “SDKs” or software development kits which are used to collect information, usage and statistics from a user’s use of a mobile application. By integrating a mobile SDK, developers can access different tools like analytics or re-engagement, or connect to ad networks to run in-app ads.
Web browsers and mobile app settings may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality may not function correctly. The "help" menu on most web browsers contains information on how to disable cookies, or you can visit www.aboutcookies.org/how-to-control-cookies.
The above tracking technologies may be deployed by us or our third party service providers on our behalf. You can find more information on our third-party service providers in the Data Sharing section of this Privacy Policy.
For more information, please see our Cookie Policy.
Confide takes reasonable and appropriate steps to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Policy. Confide uses a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure.
Some web browsers may transmit “do-not-track” (“DNT”) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our services do not currently process or respond to DNT settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
We will retain your personal information for only as long as is necessary to fulfill the purposes for which it is collected. We will retain and use your personal information to comply with our business requirements (eg, backups, archiving, prevention of fraud and abuse, analytics), legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements.
We store your personal information (such as your account information, subscription status and certain usage info for analytical purposes) for the duration of your account with us. As soon as you select “delete your account” using the in-app settings, your personal information is fully deleted and/or anonymised.
We will not retain personal information in identifiable form when the purpose(s) for which the personal information was collected have been achieved and, there is no legal or business need to retain such personally identifiable information. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems
Confide does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the Contact Us section of this Privacy Policy and we will take the appropriate measures to investigate and address the issue promptly.
Choices and Rights. As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:
If you are a resident of the EEA and you wish to exercise one of the legal rights mentioned above, you may contact us. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person.
For your protection, we may require proof of identity and verification before we can answer the above requests.
Basis for Processing Data. We may rely on the following legal grounds when it comes to processing personal information:
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
International Data Transfer. We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Policy. For example, if you are located outside of the United States, we may transfer your personal information to the United States, where Confide is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.
We only transfer personal information from the EEA to:
If you are a California resident, we process your personal data in accordance with the California Consumer Privacy Act (“CCPA”). This CCPA section of our Privacy Policy contains information required by the CCPA and supplements our Privacy Policy.
Access to Information and Data Portability Rights. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is twelve (12) months prior to the request date.
Data Deletion Rights. Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.
Exercising Your Rights. To make a request for access, portability, or deletion according to your rights under CCPA, you may contact us. California consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process ("Verifiable Consumer Request”). The Verifiable Consumer Request must:
Some personal information we maintain about consumers is not sufficiently associated with enough personal information about the consumer for us to be able to verify that it is a particular consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
Sale of Personal Information. We do not knowingly "sell" personal information that we collect from you, in accordance with the definition of "sell" in the CCPA, and will treat personal information we collect from you as subject to a do not sell request.
Shine the Light Law. California's "Shine the Light" law, Civil Code § 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. We do not currently engage in the type of sharing covered by this law and as a result, no such list exists. We do not make any representations concerning third parties that do not collect personal information directly through our services.
Miscellaneous. We will make commercially reasonable efforts to identify consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your CCPA rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request if your request is excessive, repetitive, unfounded, or overly burdensome. Also, we will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of goods or services, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale, and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting a notice on the program descriptions and terms linked to above so check them regularly.
We may update this Privacy Policy from time to time. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes to our Privacy Policy, we may also notify you by other means, such as by posting a notice on our website or mobile application or sending you a notification. By continuing to use our services after such revisions are in effect, you accept and agree to the revisions and to abide by them.
We encourage you to periodically review this Privacy Policy to learn how Confide is protecting your information.
Confide uses email as a primary communications channel to keep our customers, prospective customers and other stakeholders informed of our products and services. If you choose to unsubscribe from emails, you will immediately be placed on a “do not email” list.
Should you have any questions or comments related to Confide, please email:
You may also contact us by postal mail:
Confide, Inc.
555 W 18th Street
New York, NY 10011
Attention: Legal Department
If you have any questions relating to privacy or if you wish to exercise a legal right under applicable privacy law, please contact us here (for EEA residents) or here (for California residents). In addition, California residents may reach us by mail at the address detailed above.
All other queries should be emailed to: [email protected].