Privacy Policy

Introduction

fomo circles ("fomo," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services (collectively, the "Service").

By using fomo, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Service.

Age Requirement

fomo is intended for users aged 16 and older. During registration, we collect your date of birth to verify that you meet our minimum age requirement. If you do not meet the minimum age, you will not be able to create an account.

If we discover that an account belongs to a user under the age of 16, we will promptly terminate the account and delete all associated personal information. If you believe a user under 16 is using the Service, please contact us at privacy@fomocircles.com.

Information We Collect

Information you provide

• Account information — name, email address, phone number, date of birth, profile photo, and username
• Content you create — photos, videos, Fliks, Thoughts, comments, reactions, and messages sent through the Service
• Circle information — circles you create or join, circle names, and membership details
• Communications — messages you send to other users and feedback you provide to us

Information collected automatically

• Device information — device type, operating system, unique device identifiers, and mobile network information
• Usage data — features you use, actions you take, time and duration of activity, and content you interact with
• Log data — IP address, browser type, access times, pages viewed, and referring URLs
• Location data — approximate location based on IP address (we do not collect precise GPS location unless you explicitly enable it)

Information from third parties

If you sign in using a third-party service (such as Apple or Google), we may receive your name and email address from that provider, as permitted by your account settings.

How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve the Service
• Create and manage your account
• Enable you to communicate with other users within your circles
• Send you notifications about activity in your circles, reactions to your posts, and new messages
• Monitor and analyze usage patterns and trends to improve user experience
• Detect, prevent, and address fraud, abuse, and security issues
• Comply with legal obligations

Sharing Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• With other users — your profile information, posts, and activity are visible to members of your circles as determined by your sharing settings
• Service providers — we work with third-party companies that help us operate the Service (hosting, analytics, push notifications). These providers only access your information as needed to perform services on our behalf
• Advertising partners — we partner with Google AdMob, Amazon Publisher Services (APS), and Meta Audience Network to display ads within the Service. These partners may receive limited information such as your advertising identifier (IDFA), device information, and ad interaction data. See the Advertising section below for details
• Legal requirements — we may disclose your information if required by law, regulation, legal process, or governmental request
• Safety — we may share information when we believe it is necessary to protect the safety of our users, investigate fraud, or respond to a government request
• Business transfers — if fomo is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction

Advertising

fomo displays advertisements in certain areas of the app (such as the Explore feed) to help support the Service. We partner with three advertising networks:

• Google AdMob — policies.google.com/privacy
• Amazon Publisher Services (APS) — advertising.amazon.com/legal/privacy-notice
• Meta Audience Network — facebook.com/about/privacy

These advertising partners may collect and use limited data — including your advertising identifier (IDFA), device information, approximate location, and ad interaction data — to serve personalized advertisements. We do not share your name, email, phone number, or content with advertising partners.

App Tracking Transparency (iOS 14+)

When you first launch fomo, iOS will ask for your permission to track your activity across apps and websites owned by other companies. Granting permission enables more relevant, personalized advertising. Declining still allows ads to be shown, but they will be less personalized. You can change this choice at any time in Settings → Privacy & Security → Tracking.

Opting out of personalized advertising

• iOS — Settings → Privacy & Security → Apple Advertising → turn off Personalized Ads
• Google — adssettings.google.com
• Amazon — amazon.com/adprefs
• Meta — facebook.com/ads/preferences

We do not sell your personal information, and we do not share it for cross-context behavioral advertising as defined under California law.

Content Moderation & Reporting

We are committed to maintaining a safe environment for all users. fomo provides tools to help you control your experience and report concerns:

Reporting & blocking

• Report content — you can report any photo, video, Flik, Thought, comment, or message that you believe violates our terms or is inappropriate
• Report users — you can report user accounts that engage in harassment, abuse, or other harmful behavior
• Block users — you can block any user at any time, which prevents them from viewing your content, sending you messages, or interacting with you on the Service

How we handle reports

We review all reports and take appropriate action, which may include removing content, issuing warnings, temporarily suspending accounts, or permanently terminating accounts. We aim to review reports promptly and will notify the reporting user of the outcome when appropriate.

Prohibited content

The following content is strictly prohibited on fomo and will be removed upon discovery:

• Nudity, sexual content, or sexually exploitative material of any kind
• Content that depicts, promotes, or facilitates child exploitation or abuse
• Violent, graphic, or threatening content
• Harassment, bullying, hate speech, or discrimination
• Content that promotes self-harm or suicide
• Illegal activities or substances
• Spam, scams, or misleading content

Accounts found to be sharing child sexual abuse material (CSAM) or engaging in any form of child exploitation will be immediately terminated and reported to the National Center for Missing & Exploited Children (NCMEC) and applicable law enforcement authorities.

Data Storage & Security

Your data is stored using Google Firebase infrastructure, which provides enterprise-grade security including encryption in transit and at rest. We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

Data Retention

We retain your information only for as long as necessary to provide the Service and fulfill the purposes described in this policy. Specific retention periods include:

• Account information — retained for as long as your account is active. Upon account deletion, profile data is removed within 30 days
• Photos, videos, and posts — retained for as long as your account is active or until you delete them. When you delete content, it is removed from our active servers within 30 days
• Fliks (ephemeral content) — automatically deleted from our servers after 24 hours or after all recipients have viewed them, whichever comes first
• Messages — retained for as long as both participants maintain active accounts. Deleted messages are removed from our active servers within 30 days
• Circle data — when you leave a circle, your membership data is removed. Content you shared within the circle remains visible to other members unless you delete it before leaving
• Backups — deleted data may persist in encrypted backups for up to 90 days before being permanently purged

We may retain certain information for longer periods where required by law, for fraud prevention, or to resolve disputes.

Your Rights

Depending on your location, you may have the following rights:

• Access — request a copy of the personal data we hold about you
• Correction — request that we correct inaccurate or incomplete data
• Deletion — request that we delete your personal data
• Portability — request a copy of your data in a structured, machine-readable format
• Objection — object to our processing of your personal data
• Withdraw consent — withdraw consent where processing is based on consent

To exercise any of these rights, contact us at privacy@fomocircles.com. We will respond within 30 days.

You can delete your account at any time from the app settings. When you request account deletion:

• 30-day grace period — your account is immediately deactivated and hidden from other users. Your data is preserved for 30 days in case you change your mind.
• Account recovery — you can recover your account by signing back in within the 30-day grace period. Your profile, posts, and connections will be restored.
• Permanent deletion — after 30 days, all your data is permanently and irreversibly deleted, including your profile, posts, messages, and media.
• Audit record — we retain a minimal, anonymized record (containing no personal information) for fraud prevention and legal compliance.
• Legal holds — if your account is subject to an active safety investigation or legal proceeding, data may be preserved beyond the 30-day period as permitted under GDPR Article 17(3)(e) and applicable law.

Cookies & Tracking

Our website may use cookies and similar tracking technologies to improve your browsing experience and analyze site traffic. You can control cookies through your browser settings.

The fomo mobile app does not use cookies. We may use analytics tools to understand how the app is used, which collect anonymized usage data.

U.S. State Privacy Rights

California residents (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of your personal information
• Opt out of the sale or sharing of your personal information — we do not sell or share your personal information for cross-context behavioral advertising
• Non-discrimination for exercising your privacy rights

To exercise these rights, contact us at privacy@fomocircles.com or delete your account through the app settings.

Other U.S. states

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights under their respective state laws. To exercise your rights, please contact us at privacy@fomocircles.com.

International Data Transfers

fomo is operated from the United States. If you access the Service from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers maintain facilities. These countries may have data protection laws that differ from the laws of your country.

By using the Service, you consent to the transfer of your information to the United States and other countries as described in this policy. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy.

Children's Privacy

fomo requires all users to be at least 16 years of age. We enforce this requirement through date-of-birth verification during account registration. We do not knowingly collect personal information from anyone under the age of 16.

We do not knowingly collect personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA). Our age requirement of 16 exceeds COPPA's threshold, providing an additional layer of protection for minors.

If we learn that we have collected personal information from a user under 16, we will promptly terminate the account and delete all associated personal information.

If you are a parent or guardian and believe your child under 16 has created an account or provided us with personal information, please contact us immediately at privacy@fomocircles.com and we will take steps to remove the account and data.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy within the app and updating the "Last updated" date. Your continued use of the Service after any changes constitutes your acceptance of the updated policy.

Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: privacy@fomocircles.com
• General support: help@fomocircles.com
• Phone: (972) 658-4432
• Mail: FOMO Circles, LLC, 5473 Blair Rd Ste 100, PMB 370695, Dallas, TX 75231-4227