Privacy Policy

Last revised – APR 2023

Facta, Inc. (“Facta,” “we” or “us”) is committed to protecting the privacy of its clients (“Client,” “you” or “your”). This Privacy Policy explains how Facta collects, uses, and shares the personal information we collect from visitors to our website (“Website”). For information about how we collect and use information collected from our clients (“Client Data”) during the provision of our services (“Services”), please see Section 4 (“Client Data”) below. By accessing or using our Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

1. How We Collect and Use Information

We collect personal information from our Website visitors in order to provide them with a personalized, useful and efficient experience. The categories of information we collect may include:

  • Information you provide to us. We collect information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, we may request your personal information (e.g., name, postal address, email address, telephone number, credit/debit card number, bank account information) or your applicable business information when you register for an account or license our Services. We may also collect any information, data or communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Services (e.g., promotions, surveys, etc.).
  • Information from other sources. We may obtain information from other sources, such as third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined personal information.

We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Services-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Services, or technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so we can respond to you. For more information about your communication preferences, see Section 5 (“Control Over Your Information”) below.

2. How We Use Cookies and Other Tracking Technology To Collect Information.

We, and our third party partners, automatically collect certain types of usage information when you visit our Website, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Website, for example, the site from which you came and the site to which you are going when you leave our Website, the pages you visit, the links you click, how frequently you access the Website, whether you open emails or click the links contained in emails, whether you access the Website from multiple devices, and other actions you take on the Website. When you access our Website from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through tracking technologies to: (a) remember information so you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Website, as some features and services of our Website may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email or performed certain actions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as HTML5.

We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Section 6 (“Third Party Tracking and Online Advertising”) below.

3. How We Share Personal Information

We may share your personal information in the instances described below. For further information on your choices regarding your information, see Section 5 (“Control Over Your Information”) below.

  • We may share your personal information with third parties at your request or third party service providers or business partners who help us deliver or improve our Services or who perform services on our behalf, such as identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring site traffic.
  • We may share your information with third parties for marketing purposes.
  • We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.
  • We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms of Service.
  • If applicable, we may share your information with other companies and brands owned or controlled by Facta, and other companies owned by or under common ownership with Facta, or any organization that owns or controls Facta (i.e. a holding company) and any subsidiaries it owns. If applicable, these companies’ use of your personal information will be limited to the ways in which we may use this information under this Privacy Policy;
  • We reserve the right to transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in Facta) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Policy.

4. Client Data

During the course of providing our Services to you, you may upload data to our systems, which may include personal information or data about your end users (all of which are “Client Data”). Client Data is owned and controlled by you, and any Client Data we process on your behalf is maintained in strict confidence. We will collect and process Client Data solely on your behalf, and in accordance with our agreements with you. We do not use or disclose Client Data, except as authorized and required by you, and as provided for in our agreements with you.

5. Control Over Your Information

Email Communications. From time to time, we may send you emails regarding updates to our Website or Services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through the account options provided on the Website or Services. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below. Please note that Facta does not own or control the Client Data you upload to our Services, and we cannot modify or delete Client Data except at your request (or the request of another user at your organization), or as permitted by our Terms of Service.

7. Data Protection and Security

Data Retention. Following termination or deactivation of your user account, Facta may retain your information for a commercially reasonable time for record keeping, audit or other purposes. We retain personal information for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you or your organization, and provide the use of our Services to you or your organization (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Data Storage and Transfer. Your information may be stored and processed in the United States or any other country in which Facta or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that (1) Facta does not knowingly solicit, process, or intend to process your information, and (2) we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to: (a) the transfer of information to the U.S. or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities, and (b) the use and disclosure of information about you as described in this Privacy Policy.

Keeping Information Safe. Facta cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the absolute security of our systems. In the event any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations.

Facta’s obligations with respect to Client Data are defined in our agreements with our customers and are not included in this Privacy Policy. You (or your organization) remain responsible for the privacy and security of the Client Data that you collect and process, and for compliance with applicable data protection laws that may apply to the collection, processing and disclosure of Client Data through the Services.

8. Links to Third-Party Websites and Services

For your convenience, our Website and the Services may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Facta, we are not responsible for the content or information practices of the owners of those websites or services. We encourage you to review the privacy policies of any site or service before providing any personal information.

9. Children’s Privacy

We do not knowingly collect or solicit the personal information of children under the age of seventeen (17) without authorization by a holder of parental responsibility. If you believe that we may have collected personal information from or about a child under the age of seventeen (17), please send an email to with the subject line “Personal Data of a Minor.”

10. Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last revised” date at the top of this page. Please check back often for any updates. Your continued use of our Website or the Services after any change in this Privacy Policy will constitute your acceptance of such change.

11. Information for California Consumers

The information and rights in this section apply specifically to California residents.

In compliance with the California Consumer Privacy Act (“CCPA”), Facta does not sell, trade, or rent any Personal Information (as defined in the CCPA), nor have we done so in the preceding twelve months. Facta has not sold the Personal Information of minors under 16 years of age without first attaining affirmative authorization.

California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties' direct marketing purposes. Facta does not currently disclose Personal Information to third parties for their direct marketing purposes. Thus, upon receipt of such a request by a California consumer, and as required by California state law, we will respond with either (1) a confirmation that we have not disclosed any Personal Information to third parties for their direct marketing purposes in the previous calendar year, or (2) if our practices have changed, provide a list of all third parties to whom Personal Information was disclosed for their direct marketing purposes in the preceding calendar year, whichever is relevant. California consumers may request further information about our compliance with this law by emailing us at

Under the CCPA, California consumers have various rights regarding the Personal Information that our clients collect and process using our Services.

Note: These rights are generally exercisable against Facta’s clients and not against Facta because we are acting as a Service Provider (as defined in the CCPA) to our clients. These rights are only exercisable directly against Facta when we are determining the purposes and means of processing of your Personal Information (which we generally only do if you are an employee of one of our clients or someone we are sending marketing communications to). Thus, the description provided below is for your (and your organization’s) convenience – please reach out to our clients directly if you wish to exercise any of these rights. Some of the information that our clients are required to provide to you can be found in various sections of this Privacy Policy, or in our clients' respective privacy policies.

California consumers have the right to:

  • Request disclosure of the categories and specific pieces of Personal Information that a Business has collected about you;
  • Request disclosure of the categories of third-party sources, if any, from which a Business has collected Personal Information about you;
  • Disclosure of the Business or Commercial Purpose(s) for which your Personal Information has been collected;
  • Receive a list of the categories of third parties with whom a business has shared your Personal Information;
  • Request that a business delete any Personal Information that it has collected from you (subject to exceptions).
  • Not be discriminated against by a business (e.g. charged different rates, provided different levels of service, denied goods or services, or suggested any of the preceding) for exercising any of the individual rights granted above.
  • Designate an authorized agent to exercise any of the individual rights granted above, on your behalf.
  • Opt-out of the sale of Personal Information, if applicable.

To exercise any of your rights as a California consumer, you should contact the Facta client with which you have a direct relationship, or contact Facta directly if your relationship is only with us (e.g. personnel of our clients or our potential clients) by sending an email to Before complying with your request, our clients (or Facta) may need to verify that you (the subject of the request) are making the request. To accomplish this, you (or your authorized agent) may be requested to (1) confirm specific pieces of Personal Information that our clients (or Facta) already know about you, or (2) provide our clients (or Facta) with appropriate identification depending on the sensitivity of the information requested. California consumers are limited to two requests for Personal Information per twelve-month period.

12. Contact us

For additional inquiries about this Privacy Policy, please send us an email at, or contact us at 600 California St Floor 11, San Francisco, CA 94108.