Privacy Policy
How We Respect Your Privacy in the Fathm app
Last Update: July 22, 2021
By accessing or using the mobile application Fathm (Fathm or “the app”) whether in the free or premium versions, as set out in the Terms of Use, you consent to the information collection, use and disclosure practices described in this Privacy Policy. Fathm is owned and maintained by Socratic Sciences, Inc., a Delaware public benefit corporation, having a principal office located at 3400 N. Sycamore Dr., Boise ID 83703 (hereinafter referred to as “Company”, “we,” “us” or “our”). This Privacy Policy applies to the game and sets out how we may collect, use and disclose information in relation to the players of the game. Use of Fathm, including all materials presented herein, is subject to separate Terms of Use and this Privacy Policy.
1. Definitions
Applicable Law: means all treaties, statutes and the regulations and rules promulgated thereunder, enacted to protect the fundamental rights of individuals to privacy with respect to the collection, use, storage and processing of Personal Data, applicable to both Data Controllers and Data Processors, in the jurisdiction(s) in which the owner of any Personal Data is located.
Data: We refer to “Data” as all the information generated by you in Fathm in the course of using the app, including when players interact with customer service. Personal Data is a subset of “Data”. Data may further include information that is not about you as an individual and does not identify you but is generated through your activity and interactions in the game.
Data Controller: Also referred to as 'controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by Applicable Law, the controller or the specific criteria for its nomination may be provided for by Applicable Law;
Personal Data: means personal information which identifies or is about an identifiable individual or natural person, who is a user of the app. This information may include, in particular by reference to an identifier, such as name and email address and payment gateway details (for payment processing) and may also include Data that does not directly identify you, but can be used to reasonably identify you, such as geolocation or the serial number of your device.
Note: What is not “Personal Data” in the context of Fathm is Data derived from the exchanges among Fathm users during conversations and chats once taken out of context, de-identified and used in an aggregate manner for the continuous development of Fathm and its work products.
Your Content: Fathm enables you to post questions and participate in discussions. All such material that you upload, publish or display to others on the Fathm platform will be referred to collectively as “Your Content”.
2. Our Promise to You:
i. We collect and process Personal Data from you, on your behalf, with full transparency and with your consent;
ii. We make you fully aware of the reasons and purposes for collecting and processing your Personal Data;
iii. In accordance with our Terms of Use, we will not knowingly collect Personal Data of individuals under, nor accept players under, 18 years of age;
iv. We collect and use Personal Data only to enable you to set up an account and enjoy the game;
v. We will not hold your Personal Data nor Your Content, when you are no longer playing the game, for any longer than you have indicated in your account settings, and you can delete Your Content at any time;
vi. We will promptly attend to inquiries about your Personal Data, including requests for deletion (to request your account to be deleted please email support@socraticsciences.com) or for portability (where Applicable Law requires);
vii. We employ technical, organizational and security measures to protect your Data in the app;
viii. We do not make use of cookies or other tracking mechanisms within Fathm;
ix. Rest assured: you can fully exercise your rights with ease and without hindrance. You can contact us anytime at: Privacy@SocraticSciences.com
3. How we keep our Promise to you:
We are transparent about the Data we collect:
A. Directly from you, we collect the following categories of Data:
i. Account Registration Data so you can join the game: your first name, last name, email and password, type of account (free or premium);
ii. Device related Data so we can provide the correct functionality and prevent fraud, misuse and non-compliance with Applicable Law: device ID, serial number, IP address, platform from which you join Fathm (Apple, Google etc.);
iii. Participation and interaction Data so you can enjoy the app and we can respond to any queries: your first name, last name, groups you belong to, chat information, answers to the game questions. For more information, please consult our Terms of Use ;
iv. Usage information so that we can comply with our own Terms of Use: information about your activity, your game interactions, game performance and diagnostic related information, your use of new features, and your response to updates of our Terms of Use and updates of our policies;
B. Indirectly:
v. Personal Data and other information that you or others may disclose in conversations, including (but not limited to) the opinions and beliefs expressed by players;
vi. During communications with us, through your inquiries via info@SocraticSciences.com. Note: please do not provide more Personal Data to us than is necessary for Fathm to respond to your inquiry.
Note: We want users to be aware of other ways in which Personal Data may be collected on the Fathm platform unintentionally by us. We have implemented strong privacy and security measures to assure you that we will be very careful with your Personal Data. However, please understand that whenever you reveal Personal Data to your friends and others you trust within the game, we cannot stop them from copying or relaying that information inappropriately if they decide to circumvent the privacy and security measures, we have put in place to avoid such behavior. We encourage you to be authentic and honest, but to show as much care to sensitive, potentially embarrassing information here as you would in your other interactions with those you know.
4. We are transparent about how we use and process your Data
The Data that you provide within the game is used to allow you a rich and rewarding gameplay experience, and may be used by us to better understand how to further develop the game and enhance your experience within Fathm:
i. We do not rent or sell your Personal Data to others. We may store your Personal Data in locations outside our direct control (for instance, on servers or in databases co-located with our hosting providers);
ii. Once you have authorized us to collect your Personal Data and to provide you with access to the app, we will use your Personal Data to:
a. Verify and authorize you to join Fathm;
b. Provide you with assistance;
c. Respond to inquiries;
d. Respond to requirements in laws and regulations, or to assist with any investigations or claims (or potential claims) brought against us;
e. Provide and maintain the game;
f. Notify you about changes in our Terms of Use [provide link], and policies;
g. To create statistical Data derived from your interactions within the app.
iii. You can withdraw your consent at any time. When you have registered and joined Fathm, you will have provided us with your consent for the purposes outlined in section 3 above.
If you were to change your mind, you may withdraw your consent for collecting and using your Data, if you should so choose. For this reason, you may contact us at: Privacy@SocraticSciences.com
5. We are clear about how and why we are sharing your Data
We may disclose the Data in good faith and with the belief that such action is necessary, in order to: When necessary, and as permitted by Applicable Law, we may disclose and transfer your Data to our legal and professional advisors, regulators, law enforcement agencies, insurers, government agencies and other organizations.
i. comply with legal obligations;
ii. protect and defend our rights or property;
iii. prevent or investigate possible wrongdoing, abuse or illegal activities;
iv. identify and prevent violations of our Terms of Use [provide link] ;
v. protect the personal safety of players;
vi. protect players against legal liability;
vii. consummate a merger, acquisition or other major corporate transaction;
We offer game features that are provided by third party providers, such as Unity, OneSignal and Mixpanel, however we do not share your Personal Data with these service providers. We use their services to: monitor performance and to provide good functionality, to identify ways to improve your experience in the app and to enable push notifications inside the app. For more information on their approach to privacy, please visit the privacy policies of each:
● https://unity3d.com/legal/privacy-policy/unity-insider-privacy-policy
● https://onesignal.com/privacy_policy
● https://mixpanel.com/legal/privacy-policy
6. We take precautions when we transfer your Data between jurisdictions
i. Your Data is primarily stored on servers in the United States. If your group includes players from other countries, we may transfer your Data to affiliated entities, from your country or jurisdiction to other countries or jurisdictions around the world, while you are using the app. Your consent to this Privacy Policy followed by your submission of such information represents your consent to such ongoing transfers;
ii. We have taken steps to review and comply with Applicable Law on the transfer of Personal Data between countries to help ensure your Data is adequately protected during transfer, wherever it may be.
7. We take great care to safeguard your Data
i. We encrypt your Data;
ii. We store your Data in an encrypted format in a secure database;
iii. We provide you with the ability to delete your account and your interactions inside the game;
iv. You can join by invitation only, in small groups with players you know;
v. We do not track you inside the app;
vi. We hide comments from new users as a default setting;
vii. You can hide your comments from others at any time;
viii. We de-identify your Data when it is aggregated to provide population metrics;
ix. We assist you when you want to delete your account or your Data (to delete your account please email support@socraticsciences.com);
x. We enforce strict access controls;
xi. We do not advertise, allow advertising in the game nor share identifiable Data or activity logs with third parties;
xii. We do not sell your Data;
xiii. We respect your rights to erasure of, portability of and access to your Data;
xiv. We respond to your inquiries in a timely manner;
xv. We keep logs of activity as proof of authorized access to Data;
xvi. We only keep your Data for as long as you maintain an account in Fathm, unless we have other legal obligations.
We have implemented administrative, organizational and technical measures to safeguard your Data. We take reasonable precautions to ensure that our staff and employees who have been specifically granted access to information about you have received adequate training to ensure that they process that information only in accordance with this Privacy Policy and with our obligations under Applicable Law.
We exercise commercially reasonable efforts to safeguard the confidentiality, availability and integrity of the Data in Fathm, including cloud service provider encryption and technical safeguards. However, the security of transmission in accordance with industry standards and administered by human beings cannot be guaranteed. We will not be liable for unauthorized disclosure of Personal Data that occurs through no fault of our own, including, but not limited to, errors in transmission, access to your account by anyone other than you, uses of your player ID and password by unauthorized parties, your failure to comply with your security obligations, and unauthorized acts that contravene our Terms of Use.
Should, despite the security measures, a security breach occur that is likely to have a negative impact upon your privacy, we will inform you and the relevant authorities as required by Applicable Law.
8. Contact Us
i. Should you become aware of a violation of our Terms of Use.
Should you know of an unauthorized person being part of the game (including, but not limited to participants under 18 years of age);
Should you learn of a breach in security safeguards or of any other nature;
Should you require to ask about your account details or your Data rights and deletion choices;
Should you need to notify us of any errors, omissions, inaccuracies or other unintended errors;
Should you have any questions about the security of the app;
Should you have any other questions about our Privacy Policy,
Please contact us via email: Privacy@SocraticSciences.com
9. GDPR compliance
For users based in the European Union (EU), we make all commercially reasonable efforts to ensure that the app complies with The General Data Protection Regulation (GDPR) (EU) 2016/679 as set forth by the European Union regarding the collection, use, and retention of Data from players who are located in European Union member countries. We shall make all commercially reasonable efforts to adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
Your Rights:
Right to access
You have the right to access your Personal Data. You can contact us directly should you require more information about what Personal Data is collected and processed in the app.
Right to withdraw consent
You are consenting to disclose your Personal Data to us when you register to participate in the app. You can withdraw your consent at any time by emailing us at Privacy@socraticsciences.com. If you withdraw your consent, you can delete your account. Please note that withdrawing your consent does not affect the processing of data that may have already been extracted, de-identified, and aggregated from the game based on our Terms of Use.
Right to correct
You have the right to have incorrect or incomplete Personal Data corrected or completed. You can correct or update some of your Personal Data through your user account settings directly in the mobile application.
Right to erasure
You can contact us by email to request erasure of your Personal Data that we have collected about you. We will comply with such a request unless we have a legitimate reason to not delete the Personal Data. In such a case, we will inform you of that reason.
Right to object to processing
You can object to processing that is based on public interest or our legitimate interest or that of a third party. If we do not have a legitimate ground to continue processing such Personal Data, we will no longer process the Personal Data after your objection.
Right of restriction to processing
You can send us a request to restrict processing of your Personal Data, for example, when your Data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your Data.
Right to Data portability
You have the right to receive your Personal Data from the game in a structured and commonly used format.
You can use your rights by contacting us (the Data controller) by email provided in the Contact Us section.
Right to oppose automated individual decision-making, including profiling
You have the right granted by the European legislature not to be subject to a decision based solely on automated processing, including profiling. Our game does not involve automated processing nor individual profiling as defined the GDPR.
10. CCPA compliance
For California residents
California residents have specific rights under the California Consumer Privacy Act (‘CCPA’). For more information and to exercise your rights, please see the section headed “The California Consumer Privacy Act” below.
The California Consumer Privacy Act
Under the California Consumer Privacy Act (‘CCPA’), California residents have certain rights regarding the Personal Data (information) that businesses have about them. This includes the rights to request access or deletion of your Personal Data, as well as the right to direct a business to stop selling your Personal Data.
Please consult our “How we keep our Promise to you” section of this Privacy Policy to identify the complete list of what Personal Data we collect, for what purposes and from what sources.
With Whom We Share Your Personal Information
We share Personal Data as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)). This includes sharing identifiers, commercial information and internet or other electronic network activity with providers of platform hosting and maintenance, product feedback and technical helpdesk linked to our service providers.
We do not share Personal Data for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We do not share identifiers, commercial information and internet or other electronic network activity with advertising networks, website analytics companies, or event sponsors.
The right to opt-out of sale
Fathm does not sell Personal Data in exchange for any monetary consideration. We do not share Personal Data for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your Personal Data is collected and shared.
However, you have the right to request disclosure
You have the right to request disclosure about what categories of Personal Data Fathm has disclosed for a business purpose about you and the categories of third parties to whom the Personal Data was disclosed.
Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request:
The categories of Personal Data that we has collected about you
The categories of sources from which we collected the Personal Data
The business or commercial purpose for collecting the Personal Data
The categories of third parties with whom we share Personal Data
The specific pieces of Personal Data we collected about you
The categories of Personal Data we disclosed about you for a business purpose
If you would like to exercise your right to request disclosure, please email us. Our privacy team will examine your request and respond to you as quickly as possible.
Right to request deletion
You have the right to request that we delete any Personal Data about you that we have collected from you. Please note that there are exceptions. We do not have to fulfill a request to delete Data, if the deletion of Data would create problems with the completion of a transaction or with compliance with a legal obligation.
If you would like to exercise your right to delete, doing so is completely within your control. If you intend to delete all Your Content and to close your account, then as a courtesy, we would appreciate your emailing us to let us know that you are leaving Fathm. We may inquire about your reasons for leaving; and, while we value the feedback from players, you are under no obligation to reply.
Right to non-discrimination
The app will not discriminate against you (e.g., through denying you the right to play, or by providing a different level or quality) for exercising any of the rights afforded to you.
Contact Information
In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your Personal Data or information. California residents with inquiries or complaints regarding this Privacy Notice should first contact us at:
Privacy Officer Privacy@SocraticSciences.com
California and Delaware “Do Not Track” Disclosures
California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. The game has no relationship with advertisers. Our mobile app is an advertisement-free zone. Furthermore, the game does not use browser tracking technologies and does not have any feature that is able to interface with any “Do Not Track” setting on your phone.
11. Changes to this Privacy Policy
i. We may modify this Privacy Policy from time to time, and any such change shall be reflected within the app with the updated version of the Privacy Policy and you agree to be bound to any changes to the updated version of Privacy Policy when you use the app;
ii. You acknowledge and agree that it is your responsibility to review updates in the app and in this Privacy Policy periodically and to be aware of any modifications. Please check this Privacy Policy regularly.
iii. Also, occasionally there may be information in the game that contains unintentional typographical errors, inaccuracies or omissions, in, perhaps, descriptions, pricing, availability, and various other information about the app, and we reserve the right to correct any such errors, inaccuracies or omissions and to change or update the information at any time, without prior notice.