Privacy Policy

Effective Date: October 1, 2025

FRED COMMS LLC ("FRED," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform at getfred.app and related services (collectively, the "Service").

1. Information We Collect

1.1 Information You Provide

We collect information you voluntarily provide when creating an account or using the Service:

• Contact Information: Name, email address, phone number
• Profile Information: Railroad craft, carrier, terminal/region, union affiliation, employment verification details
• Communications: Messages, posts, and other content you share on the platform
• Support Requests: Information you provide when contacting customer support

1.2 Information Collected Automatically

When you access the Service, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages viewed, features used, referral sources
• Location Data: General location based on IP address (we do not collect precise GPS location)
• Crash Logs: App stability data, error reports, and diagnostic information
• Cookies and Similar Technologies: See Section 9 below

1.3 SMS Consent Data

When you provide consent for SMS communications, we collect and log:

• Phone number (in E.164 format)
• Timestamp of consent
• IP address at time of consent
• User agent (browser/device information)
• Consent text and version
• Page URL where consent was provided

This information is retained for compliance with telecommunications regulations (TCPA, CTIA guidelines).

1.4 Push Notification Data

When you enable push notifications, we collect:

• Device tokens (FCM/APNs)
• Notification preferences
• Delivery status

2. How We Use Your Information

We use collected information for the following purposes:

2.1 Service Delivery

• Create and manage your account
• Verify your identity and railroad employment
• Facilitate peer approval and community vetting
• Enable communication between members
• Provide customer support

2.2 Security and Authentication

• Send two-factor authentication codes via SMS
• Detect and prevent fraud, abuse, and security incidents
• Enforce our Terms of Service and Community Guidelines
• Protect the rights and safety of our users

2.3 Communications

• Send transactional SMS messages for login verification and password resets
• Send optional service notifications via SMS (security alerts, account approvals, maintenance notices) if you opt in
• Send push notifications for real-time message delivery
• Send product updates via in-app notifications
• Respond to your inquiries and support requests

2.4 Improvement and Analytics

• Analyze usage patterns to improve the Service
• Develop new features and functionality
• Monitor and analyze trends and user preferences
• Collect crash logs and diagnostic data to monitor app stability and performance

2.5 Legal Compliance

• Comply with applicable laws and regulations
• Respond to legal requests and prevent harm
• Enforce our agreements and policies

3. Sensitive Personal Information

Message Content as SPI. The content of your messages and posts may be considered "sensitive personal information" under certain state laws. We use this content only to provide and secure the Service:

• Transmit/display to intended recipients
• Detect and prevent abuse/security incidents
• Moderate content for safety and compliance

We do not use your message content for advertising, profiling, or any purposes unrelated to service delivery and security.

4. Content Moderation and Community Safety

FRED is committed to maintaining a safe and respectful community. We provide tools and take action to enforce our Terms of Use and Community Guidelines:

• Reporting Tools: In-app reporting mechanisms allow users to flag objectionable content or abusive behavior
• User Blocking: You can block other users to prevent unwanted communication
• 24-Hour Response: We commit to reviewing and taking action on user reports within 24 hours
• Content Removal: We reserve the right to remove content or suspend accounts that violate our Terms of Use

Before creating or sharing content, you must accept our Terms of Use, which defines prohibited content and user conduct standards.

5. How We Share Your Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising or targeted advertising purposes.

5.1 Within the FRED Community

• Profile Information: Your craft, carrier, and region may be visible to other verified members to facilitate relevant connections
• User Content: Posts, messages, and other content you share within the community
• Peer Approval: Local craft representatives may view limited profile information during the vetting process

5.2 Service Providers

We share information with third-party vendors who perform services on our behalf:

• Messaging services: For SMS delivery and verification
• Cloud infrastructure: For hosting, database, and network security
• Push notifications: For real-time message delivery to mobile devices
• Analytics and monitoring: For usage analytics and app performance
• Customer support: For service and communication tools

These providers act as service processors, not data purchasers. They are contractually obligated to protect your information and use it only for specified purposes. Your data is never sold.

5.3 Legal Requirements

We may disclose information if required by law or in response to:

• Court orders, subpoenas, or other legal processes
• Requests from law enforcement or government agencies
• Situations involving potential threats to safety or security
• Protection of our rights, property, or the rights of others

6. Law Enforcement and Data Requests

FRED discloses user information only in response to valid legal process and in accordance with the Stored Communications Act (18 U.S.C. §§2701–2712) and applicable law.

• We do not disclose the contents of communications to private parties
• We require a search warrant or court order for content requested by law enforcement
• Unless legally prohibited, we will notify the affected user before producing their information so they may seek to quash or limit the request

For law enforcement requests, contact: [email protected]

7. Data Security

We implement industry-standard security measures to protect your information from unauthorized access, alteration, disclosure, or destruction, including:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security monitoring
• Secure consent logging for regulatory compliance

8. Your Privacy Rights

8.1 Access and Correction

You have the right to:

• Access the personal information we hold about you
• Request corrections to inaccurate or incomplete information
• Update your profile information directly through the Service

8.2 Data Deletion

You may delete your account at any time through Settings > Account > Delete Account. Upon deletion:

• Your profile and personal information will be removed
• Your messages and posts will be deleted or anonymized
• Some data may be retained for legal compliance (SMS consent logs for at least 4 years per TCPA statute of limitations, content subject to legal holds)
• Anonymized or aggregated data may be retained for analytics

8.3 SMS Opt-Out

You can manage SMS preferences at any time:

• Reply STOP to opt out of service notifications
• Update notification preferences in Settings > Notifications

Important: Replying STOP blocks all SMS messages from our toll-free number, including login verification codes. If you opt out, you must use email-based authentication or reply START to re-enable SMS. Transactional authentication messages (login codes, password resets) do not require marketing consent under TCPA.

8.4 State-Specific Rights

California Residents (CCPA/CPRA): You have additional rights including:

• Right to Know what personal information we collect
• Right to Delete your personal information (with exceptions)
• Right to Correct inaccurate information
• Right to Limit use of sensitive personal information
• Right to non-discrimination for exercising your rights

Other States: If you are in Virginia, Colorado, Connecticut, or Utah, you have similar rights under state privacy laws. Contact us to exercise these rights.

To submit a privacy rights request: [email protected]

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and keep you logged in
• Remember your preferences and settings
• Analyze usage patterns and improve the Service
• Provide security features

You can control cookies through your browser settings, but disabling cookies may limit functionality of the Service.

10. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover that we have collected information from a child under 18, we will delete it promptly.

11. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

12. Data Retention

We retain your information for as long as necessary to:

• Provide the Service and fulfill the purposes described in this Policy
• Comply with legal obligations (e.g., SMS consent records for at least 4 years per TCPA statute of limitations)
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

When information is no longer needed, we will securely delete or anonymize it.

13. International Users

The Service is operated in the United States. If you are accessing the Service from outside the U.S., your information will be transferred to, stored, and processed in the United States, which may have different data protection laws than your country.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated Policy on the Service with a new "Effective Date"
• Sending an email notification to your registered email address
• Displaying a prominent notice on the Service

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

15. Contact Us

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