Last Updated: June 26, 2025
Introduction: Fn First Holdings LLC ("Fn First," "we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains what data we collect through our mobile applications, websites, and related services (collectively, the "Services"), how we use and share that data, and your choices regarding your information. This Policy is intended to comply with applicable privacy laws including (but not limited to) the California Consumer Privacy Act (CCPA/CPRA), Canada's PIPEDA, the EU/UK General Data Protection Regulation (GDPR), and other relevant laws for our global users.
This Privacy Policy applies to personal information we collect from you:
This Policy does not apply to data processing by third-party platforms that distribute or host our Services (such as Apple's App Store or Google Play Store) except to the extent those platforms pass your data to us. For example, if Apple or Google provides us information for subscription validation or sign-in, this Policy governs how we handle that information once we receive it. Be sure to review the privacy policies of any platform or service you use to download or access our Services.
We only collect personal information that is necessary to provide and improve our Services, or as required by law. Below is an overview of categories of data we collect, with examples and purposes:
Category | Typical Data Points | Purpose & Legal Basis |
---|---|---|
Account & Subscription Data |
– Identifiers: Unique user ID (for Apple Sign-in, an Apple-provided identifier), email address (if you create an account via email/password or if Apple Sign-In provides it), display name (if you choose to provide one). – Subscription info: Subscription tier (e.g., Free, Premium, VIP), purchase receipts or transaction IDs, subscription status and renewal dates. |
Purpose: To create and maintain your account, allow login, verify and manage purchases (e.g., check your subscription status), and deliver the features you are entitled to. Legal Basis: Fulfillment of contract (GDPR Art. 6(1)(b)) – we need this info to provide the Services you signed up for; plus our legitimate interest in fraud prevention and service security. |
Authentication Data |
– Credentials: If you use email/password, the email and hashed password are stored via our auth provider (Firebase). – Third-Party Auth Tokens: If using Sign in with Apple, we receive a token and any user info Apple shares (like name/email if not hidden). |
Purpose: To let you securely log into our Services and sync your data across devices, and (if you consent) derive a hashed key for first-party product-analytics cohorts. We use third-party authentication (Apple Identity, Firebase) to handle login securely. Legal Basis: Fulfillment of contract (to provide you access to your account) and legitimate interest in account security. |
Anonymous Session ID | Random UUID created on first launch, stored in Firebase and Keychain, not linked to name or email |
Purpose: Authenticate requests, enforce usage limits, prevent fraud. Legal Basis: Legitimate interest in service security (GDPR Art 6-f). |
Usage Data (Analytics) |
– Device info: Device model, OS version (e.g., iOS 17), app version. – App usage events: Feature usage stats, session length, crashes or error reports. (Analytics are opt-in where required.) |
Purpose: To understand how users interact with our Services and improve stability, features, and user experience. For example, knowing which features are most used helps us focus development, and crash reports help us fix bugs. Legal Basis: Legitimate interests (GDPR Art. 6(1)(f)) in improving our Services. Where required by law, we will obtain your consent for analytics. |
Support & Feedback Data |
– Contact info: Email address and/or phone number (if you provide it when contacting support). – Content of communications: Any details you provide when seeking support (such as screenshots, logs, or descriptions of a problem), and correspondence history. |
Purpose: To assist you when you contact us, to troubleshoot issues, and to improve the Service based on feedback. If you email support, we use your email to communicate with you and resolve your inquiry. Legal Basis: Fulfillment of contract (answering your questions as part of customer support) and legitimate interest in maintaining high-quality service. |
Marketing (Opt-In) |
– Identifiers: First name, email address, region (if you subscribe to a newsletter or promotional updates). – Marketing preferences: Your consent choices for receiving marketing emails. |
Purpose: To send you updates, newsletters, or promotional offers only if you have opted in. For example, if you join our mailing list, we may send product news or special offers. Legal Basis: Consent (GDPR Art. 6(1)(a)). You can withdraw consent at any time (each marketing email will have an "unsubscribe" link). |
Payment Data | – None collected by Fn First. When you make a purchase, all payment processing (credit card, etc.) is handled by Apple or Google. We do not receive your credit card number or financial info. We only receive confirmation of payment and basic subscription details from the platform. |
Purpose: Not applicable for payment card data since we don't collect it. For purchase confirmations, we use receipt info to activate your premium features and maintain access as long as you're subscribed. Legal Basis: Fulfillment of contract – to grant the service you paid for. |
We do not knowingly collect any sensitive personal data such as precise GPS location, health or medical data, biometric identifiers, or data on children under 16. If you believe a child under 16 has provided personal data to us, please contact us so we can remove it.
We use the collected information for the following purposes:
We do not use your personal information for any purposes incompatible with those above. Importantly, we do not sell or rent your personal data to third-party advertisers or marketers. Any analytics we perform is primarily to improve user experience, and where possible, we use aggregated or anonymized data.
Fn First understands the importance of keeping your information private. We only share your personal data in a few specific scenarios, outlined below:
We do not share personal information with advertisers or social media companies for their independent marketing purposes. Any sharing that occurs is mainly to support functionality (like cloud processing) or because you initiate it (like sharing content with others).
International Data Transfers: Our servers and service providers are primarily located in the United States. If you reside outside the U.S., be aware that your data may be transferred to and stored on servers in the U.S. or other jurisdictions that may not have the same data protection laws as your home country. However, if you are outside the U.S., we will take steps to ensure appropriate safeguards (such as Standard Contractual Clauses for EU personal data) are in place to protect your information. We strive to abide by the data residency requirements of our users' regions to the extent feasible.
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Below are our general retention practices:
When we no longer have a legitimate need or legal obligation to retain your personal information, we will securely delete it or anonymize it.
We take data security seriously and implement reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access or disclosure. Our security measures include:
Please note that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. You also play a role in security: keep your account credentials confidential and use a unique, strong password. If you suspect any unauthorized access to your account, please let us know immediately.
Depending on your jurisdiction, you may have certain rights regarding your personal information. We honor all users' rights as applicable under their local laws. These may include:
To exercise any of your rights, please contact us at [email protected] or via the contact form on our website (fnfirst.com/contact). For security, we will need to verify your identity before acting on a data request (for example, by confirming ownership of your email address or other information). We aim to respond to requests within 30 days (or as required by law, 45 days under CCPA for example). If we need more time, we will inform you of the reason and extension period.
EU/UK Users: Fn First Holdings LLC is the controller of your personal data. Our legal bases for processing are as stated in Section 2. We have appointed an EU representative [if applicable, include details] or you may contact us directly with any questions. You have the rights under the GDPR as outlined in Section 7 above. If we transfer your data outside the EU, we rely on Standard Contractual Clauses (SCCs) or other legally approved mechanisms for such transfers, as mentioned in Sharing section.
California Users: Under the CCPA/CPRA, California residents have specific rights, some of which overlap with GDPR rights described above (access, deletion, etc.), and also the right to know what categories of personal information are collected, from where, the business purpose, and the categories of third parties we share with. We believe this Policy provides those details: see Section 2 (categories, sources, purposes) and Section 4 (sharing). We do not "sell" or "share" personal information as defined under the CCPA (we don't provide your data to third parties for their own marketing). If you send a request to exercise California rights, we will process it per applicable law. If you have an authorized agent you want to submit a request on your behalf, we will require proof of authorization and still take steps to verify your identity directly with you.
Other Regions: We strive to honor the privacy rights of users in all jurisdictions. If your local laws provide any privacy rights not explicitly listed here, we commit to respecting those as well. You can contact us to inquire about your specific privacy concerns.
Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from anyone under 16. If you are under 16, please do not use our Services or provide any information about yourself to us (including name, email, etc.). In the event we learn that we have inadvertently collected personal data from a child under 16, we will take immediate steps to delete such information from our records. If you are a parent or guardian and believe we might have any information from or about a minor under 16, please contact us so that we can promptly investigate and address it.
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the "Last Updated" date at the top of this Policy. If changes are material, we will provide advance notice to you of the changes – for example, by posting a notice on our website or in-app, or by emailing users (when appropriate) – at least 7 days before the changes take effect. We encourage you to review this Policy periodically for the latest information on our privacy practices. By continuing to use our Services after any update becomes effective, you acknowledge and accept the revised Privacy Policy.
While our Services are not platforms for user-shared public content (no social networking features), we provide the following information in the interest of transparency and compliance with the EU Digital Services Act for users in the EU:
This DSA notice is provided to give you insight into how our Services operate in terms of content and algorithms. For any concerns regarding illegal content or misuse, please reach out via the contact information below.
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:
Fn First Holdings LLC
Attn: Privacy Officer
30 N Gould St Ste N
Sheridan, WY 82801 USA
Email: [email protected]
You may also reach general support at [email protected] for non-privacy queries.
We will do our best to address any issue to your satisfaction. Your privacy is important to us, and we welcome your feedback.
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