Legal
Privacy Policy
The Fleat Privacy Policy explains how we collect, use, disclose, retain, and otherwise process personal information in connection with the Fleat platform and other services we make available to Vendors, Organizers, Visitors, and other users (the “Platform”).
1. Welcome
Fleat LLC and our affiliated entities (“we”, “us”, “our”, or “Fleat”), respect your privacy. That’s why we strive to minimize the personal information we process through the Platform and provide information about the choices and rights described in this Fleat Privacy Policy (“Policy”).
The basics
Please read this Policy in full before you use the Platform. At the outset, you should know that:
- We collect and process personal information reasonably necessary to provide, operate, secure, support, and improve the Platform. Depending on how you use Fleat, this may include account and contact information, Vendor or Organizer profile information, applications, permits, licenses, certifications and other documents you upload, communications, booking and transaction information, payment-related information, and information about your use of the Platform.
- We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable privacy law. We may disclose personal information to Organizers, Vendors, service providers, Payment Providers, and other parties as described in this Policy when necessary to provide or operate the Platform.
- The Platform is primarily designed to support Organizers and Vendors. Fleat generally does not collect information about a Vendor’s retail customers or transactions between Vendors and consumers purchasing their products. However, Fleat may collect or receive limited information relating to Visitors, shoppers, attendees, or other individuals who interact with public portions of Fleat Network or with Organizer features powered by the Platform, including payment or admission functionality. Complete payment-card information is generally collected and processed directly by our Payment Providers rather than Fleat.
By accessing or using the Platform, you acknowledge that this Policy describes Fleat’s privacy practices in connection with your use of the Platform. Your use of the Platform is also subject to our Terms of Service, available at https://terms.myfleat.com/ (the “Terms”).
Your access to and use of the Platform are subject to the Terms. If you do not agree to the Terms, you must not access or use the Platform. Capitalized terms used but not defined in this Policy have the meanings given to them in our Terms. If you have questions about this Policy, please contact us at support@myfleat.com.
Updates to this Policy
As the Platform changes, we’ll update this Policy. When required by applicable law, we will provide notice of material changes to our privacy practices before those changes take effect. Such notice may be provided through the Platform, by email, by posting an updated Policy, at the point where personal information is collected, or by another method appropriate to the nature of the change and required by applicable law.
We will update the “Last Updated” date when this Policy changes. We encourage you to review this Policy periodically for information about our current privacy practices.
Contact Us
You may contact us regarding the Platform or this Policy at support@myfleat.com or by writing to us at 1420 N. Alta Vista Blvd, Ste. 122, Los Angeles, California 90046.
2. Info we collect & how we use it
This table describes the categories of personal information we may collect, examples of that information, the sources from which we collect it, how we use and disclose it, and the criteria we use to determine how long we retain it. The information Fleat collects depends on how you interact with the Platform, and not every category applies to every user.
We may also deidentify or aggregate information so that it is no longer reasonably capable of being associated with an identifiable individual. We may use such deidentified or aggregated information to operate and improve the Platform, develop new products or services, analyze usage, and for other lawful purposes.
| Category and Examples | Sources | How We Use It | How We May Disclose It | Retention |
|---|---|---|---|---|
| Account and Contact Information: Name, business or trade name, email address, phone number, mailing or business address, account identifiers, authentication information, and similar contact or account information. | Directly from you; from an Organizer or Vendor that creates or provides information relating to you; or from supported authentication providers. | To create and administer accounts; authenticate users; provide support; send or facilitate service messages, reminders, and other communications requested through the Platform; communicate service notices; operate and secure the Platform; manage relationships with Organizers and Vendors; and, where permitted, send marketing or promotional communications. | Service providers that help us operate the Platform; authentication and communications providers; Organizers or Vendors where necessary for your interactions with them; and other parties as described in this Policy. | Generally for the duration of your account or relationship with Fleat and thereafter for as long as reasonably necessary for legitimate business, security, legal, accounting, dispute-resolution, or compliance purposes. |
| Vendor, Organizer, Application, and Profile Information: Business descriptions, products or services offered, photographs, market preferences, application responses, space or booth information, participation history, public profile information, and other information submitted in connection with an Organizer, Vendor, market, or event. | Directly from you; from Organizers or Vendors with whom you interact; through your activity on the Platform; or, for certain public listings, from publicly available sources. | To provide Vendor profiles and market listings; facilitate discovery, applications, bookings, and participation; manage Vendor and Organizer relationships; operate Fleat Network, Fleat Lite, and Fleat Ops; and improve the Platform. | Organizers and Vendors with whom you choose to interact; Visitors where information is designated for public display; service providers; and other parties as described in this Policy. | For as long as the applicable profile, account, listing, application, transaction, or relationship remains active and thereafter as reasonably necessary for recordkeeping, dispute-resolution, legal, security, and operational purposes. |
| Permits, Licenses, Certifications, and Other Documents: Permits, licenses, certificates, insurance documents, identification information, and other documents or credentials that you choose or are required to provide through supported Platform features. These documents may contain personal or sensitive personal information. | Directly from you or, where appropriate, from an Organizer or other user authorized to provide the information. | To facilitate applications and participation requirements; permit Organizers to review Vendor qualifications or documentation; maintain reusable Vendor records; provide requested Platform functionality; prevent fraud; and satisfy legal or compliance requirements. | Organizers with whom the information is shared in connection with an application, booking, or other relationship; service providers that provide hosting, storage, security, or related infrastructure; and other parties where required by law or described in this Policy. | For as long as reasonably necessary to provide the applicable feature or maintain relevant Organizer or Vendor records, and thereafter where reasonably necessary for legal, compliance, fraud-prevention, security, or dispute-resolution purposes. |
| Transaction and Payment-Related Information: Transaction amounts, dates, payment status, transaction identifiers, refunds, disputes, chargebacks, Organizer Proceeds, and limited payment-method information provided to Fleat by a Payment Provider. Fleat generally does not receive or store complete payment-card numbers or payment credentials processed directly by a Payment Provider. | From you; from Organizers or Vendors involved in the transaction; and from Payment Providers. | To process and administer transactions; calculate fees and Organizer Proceeds; process refunds and disputes; provide transaction records; prevent fraud; reconcile payments; provide support; and comply with accounting, tax, legal, or regulatory obligations. | Payment Providers; the Organizer or Vendor involved in the transaction; financial, accounting, legal, or compliance service providers where appropriate; and authorities where legally required. | For as long as reasonably necessary to administer the transaction and thereafter for applicable accounting, tax, legal, fraud-prevention, compliance, and dispute-resolution purposes. |
| Communications and Support Information: Messages exchanged through Platform features, communications with Fleat support, requests, feedback, and information or files included in those communications. | Directly from you and from other users who communicate with you or with Fleat. | To deliver communications; provide customer support; respond to requests; investigate issues; enforce our Terms; prevent misuse; and improve the Platform. | Intended recipients of communications; service providers that support communications or customer service; and other parties where necessary to investigate abuse, comply with law, or as otherwise described in this Policy. | For as long as reasonably necessary to provide the relevant communication or support function and thereafter as reasonably necessary for operational, security, legal, or dispute-resolution purposes. |
| Device, Usage, and Security Information: IP address, browser and device information, approximate location derived from IP address, referral information, login activity, page views, button clicks, navigation patterns, cookies or similar identifiers, and information about how the Platform is accessed and used. | Automatically from your browser, device, and use of the Platform; through first-party technologies and analytics, security, or infrastructure providers. | To operate and secure the Platform; authenticate users; detect fraud, abuse, or unauthorized activity; troubleshoot performance; understand how the Platform is used; improve features and usability; and measure communications or marketing where permitted. | Hosting, analytics, security, infrastructure, and other service providers that process the information on our behalf; and other parties where required by law or described in this Policy. | For periods reasonably necessary for security, analytics, troubleshooting, and operational purposes, after which information may be deleted or deidentified, subject to legal, security, and backup requirements. |
| Information From Other Users, Service Providers, and Public Sources: Information an Organizer provides about a Vendor, information received from Payment Providers or authentication providers, and information concerning markets, events, businesses, or other matters obtained from publicly available sources. | Organizers, Vendors, Payment Providers, authentication providers, other service providers, and publicly available sources. | To create and maintain Platform records and public listings; facilitate Organizer-Vendor relationships; verify or supplement information; provide requested integrations; prevent fraud; and operate and improve the Platform. | As appropriate to the underlying feature or relationship, including with relevant Organizers or Vendors, Visitors where information is publicly displayed, service providers, and other parties as described in this Policy. | For as long as reasonably necessary for the purpose for which the information was obtained and thereafter as permitted or required for legitimate operational, security, legal, or compliance purposes. |
- Some browsers provide “Do Not Track” signals. Because there is not currently a uniform industry standard for responding to such signals, the Platform does not currently respond to browser Do Not Track signals. We use analytics and service providers as described in this Policy. We do not permit third parties to collect personal information through the Platform over time and across unaffiliated websites or services for their own cross-context behavioral advertising purposes.
- Sensitive Personal Information. Documents that Vendors upload, such as government identification, licenses, or permits, may contain sensitive personal information. We use and disclose sensitive personal information only as reasonably necessary to provide the features you request, verify documentation, prevent fraud, secure the Platform, and comply with law. We do not use sensitive personal information to infer characteristics about you. Documents stored in a Fleat Network profile are shared with an Organizer only when you choose to include them in an application, booking, or other interaction with that Organizer. An Organizer that receives a document may retain the copy it received.
Information Storage and Security
We use commercially reasonable administrative, technical, and organizational safeguards to help protect your personal information from unauthorized access, use, alteration, or disclosure. However, no method of transmission, storage, or information-security system is completely secure, and we cannot guarantee the absolute security of your information. You are also responsible for maintaining the security of your account and authentication credentials and for promptly notifying us of suspected unauthorized access.
We primarily receive, store, and process information in the United States. We may also use service providers, processors, and other vendors that process or store information in the United States or other countries. As a result, your information may be transferred to, stored in, or processed in jurisdictions with privacy and data-protection laws that differ from those where you live. Where required by applicable law, we use appropriate contractual or other safeguards for such transfers.
3. Our disclosures of information
This section describes the ways Fleat may disclose your information.
- We do not sell or “share” your personal information: We do not sell personal information for monetary or other valuable consideration or “share” personal information for cross-context behavioral advertising, as those terms are defined under applicable privacy law. This does not include disclosures that you direct or request, information you choose to make public, or disclosures to service providers, contractors, Organizers, Vendors, Payment Providers, or other parties for the purposes described in this Policy. To the extent applicable law requires disclosure of our practices during the preceding twelve (12) months, we have not sold or shared personal information for cross-context behavioral advertising during that period.
- With Organizers, Vendors, and other users: We disclose information as reasonably necessary to provide the features you request and facilitate relationships through the Platform. For example, when a Vendor submits an application, makes a booking, uploads documentation for review, communicates with an Organizer, or otherwise interacts with an Organizer, we may disclose relevant profile, application, contact, transaction, permit, license, certification, or other information to that Organizer. Similarly, we may disclose information provided by an Organizer to Vendors where necessary to facilitate applications, bookings, transactions, communications, or participation in a market or event.
- With the public: Certain Fleat Network features are designed to make information publicly available. Information that you choose to publish or designate for public display, such as a business or trade name, public profile, business description, photographs, products or services, market or event information, and similar content, may be accessible to Visitors and other members of the public. Fleat may also display publicly available information concerning markets, events, businesses, and Vendors as described in this Policy. You should not include sensitive or confidential personal information in fields or content intended for public display.
- With your consent or at your request: We may disclose personal information with your consent, at your direction, or when you otherwise request that we disclose information to another person or service.
- With service providers and contractors: We rely on service providers and contractors to facilitate some operations of the Platform. These providers may process personal information on our behalf to provide services such as cloud hosting and storage, database infrastructure, security, analytics, communications, customer support, authentication, software development, and other services necessary to operate and improve the Platform. Where required by applicable law, we require service providers and contractors to process personal information subject to appropriate contractual restrictions.
- With Payment Providers: We disclose and receive information as necessary to facilitate payments, payouts, refunds, disputes, chargebacks, fraud prevention, and related payment functions through Payment Providers such as Stripe, Inc. Payment Providers may collect payment credentials directly from you and process information pursuant to their own terms and privacy practices. Fleat generally does not receive or store complete payment-card numbers or payment credentials processed directly by a Payment Provider.
- To comply with applicable law and protect rights: We may disclose your information as reasonably necessary to comply with legal, tax, regulatory, and accounting requirements. We may disclose information where compelled, required, or otherwise permitted under applicable law, including in response to subpoenas and other lawful requests by public authorities, to detect or prevent fraud or unlawful activity, protect the security and integrity of the Platform, enforce our Terms, establish or defend legal claims, or protect the rights, property, or safety of Fleat, our users, or others.
- In connection with a corporate transaction involving Fleat: In the context of a reorganization, merger, acquisition, financing, sale of assets, change of control, bankruptcy, or similar corporate transaction, we may transfer your personal information to an actual or prospective buyer, investor, successor, affiliate, assignee, or other participant in the transaction, subject to applicable law.
- SMS. Mobile phone numbers and SMS opt-in consent collected through the Platform are not shared with, sold to, or rented to third parties or affiliates for their marketing or promotional purposes. Text message recipients may reply STOP to opt out or HELP for assistance. Message frequency varies. Message and data rates may apply.
- Information Processed on Behalf of Organizers. When Organizers use Fleat Ops or Fleat Lite, Fleat processes certain information, such as an Organizer's imported vendor lists and its booking and transaction records, on the Organizer's behalf to provide those services. Fleat separately and independently processes information for the purposes described in this Policy, including account administration, security, billing, payments, analytics, and operating Fleat Network. Requests concerning an Organizer's own use of Vendor information, including information the Organizer retains in its own records, may need to be directed to that Organizer. If we receive such a request, we may forward it to the Organizer or direct you to contact the Organizer.
4. How long we keep your information
We maintain your information for the time necessary to fulfill the purpose for which it was collected, as generally specified under Info We Collect & How We Use It. You acknowledge that longer retention may be necessary or required to comply with applicable legal, tax, accounting, security, fraud-prevention, dispute-resolution, and regulatory requirements.
Our retention determinations consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, the purposes for which we process the information, applicable legal or contractual requirements, and whether we can achieve the purpose for which it was collected without retaining the personal information.
5. No children
You must be at least 18 years old to create an account or use account-based features of the Platform, as described in our Terms. Publicly accessible portions of the Platform may be viewed by Visitors without an account. The Platform is not directed to children under the age of 13, and we do not knowingly collect personal information directly from children under 13. If we learn that we have collected personal information from a child under 13 in a manner not permitted by applicable law, we will take reasonable steps to delete it.
- If you are under 18, you may not create an account or use account-based features of the Platform. If you have created an account or provided personal information through an account-based feature, please contact us.
- If you are a parent or guardian and believe that a child under 13 has provided personal information directly to us, please contact us.
6. How to control your privacy
You have certain choices regarding how we treat your personal information, described below:
- Modifications to Platform information: You may review and update certain personal information on the Platform by editing your profile directly where that functionality is available, or by contacting us. If you provide us with updated information, we will make good-faith efforts to make requested changes where appropriate and reasonably practicable, subject to applicable legal, security, recordkeeping, and other requirements.
- Public and profile information: Certain Fleat Network information may be publicly displayed as described in this Policy. Where the Platform provides settings or controls regarding the visibility of profile information or other content, you may use those controls to manage what information is displayed publicly. You may also contact us with questions or requests concerning publicly displayed information.
- Marketing communications: You can opt out of promotional marketing communications by unsubscribing through the Platform or through an unsubscribe mechanism included in the communication, where available, or by contacting us. We may give you the option to opt out of other emails and communications you receive from us. If you opt out, we may still send you non-promotional communications, such as those about your account, transactions, security, legal notices, or our ongoing business relationship with you.
- Rights under applicable privacy laws: Depending on where you live and the laws applicable to Fleat, you may have additional rights regarding your personal information, including rights to access, correct, or delete certain information. Please follow the instructions under Requesting Information to exercise applicable rights.
Requesting Information
Submitting requests: To exercise any rights described in this Policy, you or, where permitted by applicable law, your authorized agent may contact us. Your request should:
- provide sufficient information to allow us to identify you, locate relevant information, and understand the right you are seeking to exercise, such as your name, email, mailing address, or other information we maintain; and
- not include Social Security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, health information, or other sensitive information unless we specifically request it for a lawful and necessary purpose.
Verifying requests: We verify requests by matching information submitted with information we maintain and using other reasonable verification methods appropriate to the nature of the request and information involved. We will request only information reasonably necessary to verify the request. If your request is unclear or we are unable to verify your identity, we will respond with direction on how to remedy the deficiencies, where required or appropriate under applicable law. If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.
Responses to requests: We will respond to your request as quickly as reasonably practicable, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but we will respond in accordance with any deadlines or requirements specified by applicable law.
Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable, and unreasonable risk to the security of personal information, an account, or our systems or networks, or where another exception under applicable law applies.
Please understand, however, that we may need to retain certain data as described under How long we keep your information. Deletion rights generally do not apply to information that has been deidentified or aggregated so that it is no longer reasonably capable of being associated with you, subject to applicable law.
Appealing decisions: Where applicable law provides you with a right to appeal a decision regarding a privacy request, you may submit an appeal by contacting us. We will process eligible appeals in accordance with the requirements and timeframes of applicable law.
7. State Privacy Rights
Depending on where you live and whether applicable privacy law applies to Fleat, you may have additional rights regarding your personal information. We will honor privacy rights required by applicable law.
Depending on applicable law, these rights may include the right to:
- access or obtain information about certain personal information we maintain about you;
- receive a portable copy of certain personal information;
- correct inaccurate personal information;
- request deletion of certain personal information;
- opt out of certain processing, such as the sale of personal information, targeted advertising, or certain profiling, where applicable; and
- exercise applicable privacy rights without unlawful discrimination or retaliation.
As described elsewhere in this Policy, Fleat does not sell personal information or “share” personal information for cross-context behavioral advertising as those terms are defined under applicable privacy law. Accordingly, certain opt-out rights relating to those activities may not apply to Fleat’s current practices.
Certain information may be exempt from a privacy request under applicable law. For example, we may need to retain certain information in order to provide our services, maintain transaction or security records, prevent fraud, exercise or defend legal claims, comply with law, or for other purposes permitted by applicable law.
You may exercise applicable rights as described under Requesting Information above. We may request information reasonably necessary to verify your identity or authority to make a request.