The privacy of your data is a big deal to us. In this policy, we lay out what data we collect and why, how your data is handled, and your rights with respect to your data.

We will never sell your data.

This policy applies to all products built and maintained by Fact Pattern, LLC (Fact Pattern).

This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Fact Pattern). We refer collectively to these categories of individuals as “you” throughout this policy.

What We Collect & Why

Our guiding principle is to collect only what we need. Here’s what that means in practice—

Identity & Access

When you sign up for a Fact Pattern product, we ask for identifying information such as your name and email address. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We may sometimes also give you the option to add a profile picture that displays in our products.

We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission.

Billing Information

If you sign up for a paid Fact Pattern product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Fact Pattern servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Voluntary Correspondence

When you email Fact Pattern with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When We Access or Disclose Your Information

To provide products or services you’ve requested. We use third party subprocessors, such as cloud computing providers and customer support software to help run our applications and provide the services to you. For now, these providers are Amazon Web Services and Heroku (for cloud computing), Stripe (for payment processing), Postmark (for transaction email), HEY (for email and CRM), and Kit (for mailing lists).

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law. Fact Pattern is a U.S. company and all data infrastructure is located in the U.S.

• Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if U.S. law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside the U.S. if compelled by the U.S. government through procedures outlined in a mutual legal assistance treaty or agreement. It is Fact Pattern’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
• Preservation requests. Similarly, Fact Pattern’s policy is to comply with requests to preserve data only if compelled by the U.S. Federal Stored Communications Act, 18 U.S.C. Section 2703(f), or by a properly served U.S. subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.
• If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Fact Pattern is acquired by or merges with another company, we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

How We Secure Your Data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser.

We use encryption at rest throughout our platform.

For Consular Intelligence, your password never leaves your browser during registration or login.

For Enhanced Visa Bulletin, your password is only ever stored in hashed form in our database.

In both cases, we use a cryptographic hash to authenticate you.

Data Retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of Site & Data

Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or services and/or providing us with your personal information, you consent to this transfer.

Changes & Questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.

If you have a question about this policy, please contact us.