Legal
Privacy policy
Effective 20 September 2026. Last updated 20 September 2026.
This policy explains what personal information FOGLE collects, why we collect it, who processes it on our behalf, how we use artificial intelligence, and how to have your information deleted. It is written to be read, not to be survived.
1. Who we are and how to reach us
FOGLE provides 3D interactive infrastructure planning software to municipal government. For the information described here, FOGLE is the controller, which means we decide what is collected and why.
| Service | FOGLE |
|---|---|
| Contact for anything in this policy | Fogle.HQ@gmail.com |
| Privacy and deletion requests | Fogle.HQ@gmail.com, subject line Privacy request |
| Security reports | Fogle.HQ@gmail.com, subject line Security |
| Principal place of business | Massachusetts, United States |
| Where information is processed | United States |
One address handles all three so nothing sits in an unmonitored mailbox. Use the subject lines above and your message is routed correctly.
2. Information we collect
We do collect personal information. This is all of it.
Information you give us
| Where | What |
|---|---|
| Demo request form | Your name, town or city, role, work email address, and anything you type into the notes field |
| Creating an account | Your name, work email address, role, optionally your department, and a password |
| Setting up a model | The municipality you choose, the layers you select, and any notes you add |
| Email to us | Whatever you write, and the address you write from |
| The assistant on this site | Text you type into it |
Passwords. We never see your password. It is sent directly to our authentication provider over an encrypted connection and stored there as a salted hash. Nobody at FOGLE can read it, and nobody at FOGLE will ever ask you for it.
The assistant. It runs entirely in your browser and matches your wording against the published content of this site. What you type is not transmitted to us or to anyone else. If that ever changes, the assistant panel will say so before you use it and this policy will be updated first.
Information collected automatically
- Server and platform logs. Our hosting provider and our database provider record the IP address, user agent, requested path, response status and timestamp of requests. These exist to keep the service running and to investigate abuse.
- Measurement. Only if you accept it in the cookie banner. We then record page views, referring site, approximate country, device type, and which product events occur, for example which view mode was selected. No advertising identifier is set and you are not followed to other sites.
- Campaign parameters. If you arrive through a link carrying utm parameters, those values are held in your browser for that visit and attached to a demo request if you send one, so we know which campaign produced the enquiry.
Information stored only in your own browser
- Your light or dark appearance choice.
- Your answer to the cookie banner.
- Campaign parameters for the current visit.
- If you use the town picker without an account, the answers you gave it.
These live in local and session storage on your device. They are readable only by this site, are never sent to us, and clearing your browser data removes them.
What we do not collect
- We do not collect payment card details on this website.
- We do not collect Social Security numbers, driver's licence numbers, financial account numbers, or any other identifier that would make this personal information under Massachusetts General Laws chapter 93H.
- We do not request or store owner names or mailing addresses from assessor records, even though those are public. Compiling them into a browsable map of every household is a different thing from looking one up, and a planning tool does not need it.
- We do not sell personal information, we do not share it for cross context behavioural advertising, and we do not build profiles of individuals for marketing.
3. Why we collect it
| Purpose | Information used | Basis |
|---|---|---|
| Reply to a demo request and prepare a model of your town | Name, town, role, email, notes | Steps taken at your request before entering a contract |
| Provide the product to a municipality under contract | Account details, municipal data | Performance of a contract |
| Keep the service available and investigate abuse | Server and platform logs | Our legitimate interest in a secure service |
| Understand which parts of the site are useful | Measurement events | Your consent |
| Meet legal, tax and records obligations | Contract and billing records | Legal obligation |
4. How we use artificial intelligence
Artificial intelligence appears in two places, and we would rather you knew about both before you used the product than discovered them afterwards.
In the product
FOGLE applies machine learning to infrastructure data to detect patterns across layers, for example road segments whose pavement condition, traffic load and flood exposure combine into elevated failure risk. These models run on infrastructure and geospatial data. They do not run on the personal information of residents, and they are not used to make decisions about individuals.
Every automated result is shown together with the source layers and values that produced it, so staff can check the reasoning. Automated output is an input to professional judgement and is never presented as a final determination. Where a municipality asks, we will document the model version and inputs behind a given result for the public record.
Nothing in the product makes an automated decision that produces a legal or similarly significant effect on an individual. If that ever changes, you will be told before it does, and any state law right to opt out of profiling will be honoured.
On this website
The assistant answers questions by matching your wording against published site content. It is automated, it can be wrong, and it says so when it does not know. It declines questions about credentials, security bypasses, and legal, medical or financial advice, and points you to a person instead. It runs in your browser and sends nothing to us.
5. Third parties that process information
We use a small number of processors. Each may use your information only to provide its service to us, and each is bound by its own data processing terms.
| Who | What it does | What it can see |
|---|---|---|
| Supabase | Accounts, authentication and the application database | Account details, saved models, demo requests, platform logs |
| Our static hosting provider | Serves this website | Server logs: IP address, user agent, requested path |
| Google (Gmail) | Receives and stores our business correspondence | Messages you send us and our replies |
| Google Fonts | Serves the two typefaces used here | Your IP address and user agent when the font files are fetched |
| jsDelivr | Serves two open source browser libraries | Your IP address and user agent when those files are fetched |
| OpenStreetMap Foundation (Nominatim) | Looks up a town boundary when you type a town name | The town name you typed, and your IP address |
| Plausible Analytics | Aggregate measurement, loaded only after you accept | Page views and product events, with no cookie and no advertising identifier |
This list is published here rather than buried in a contract annex only customers can read. If we add a processor, this table is updated before that processor handles anything.
We disclose information to no one else, except where we are legally required to, or where it is necessary to establish or defend a legal claim. If we are ever compelled to hand over municipal data, we will tell the municipality unless we are legally prohibited from doing so.
6. Municipal data held in the product
Data a municipality provides, such as parcel records, zoning layers, pavement condition and utility networks, belongs to that municipality. We process it only to provide the service. We do not use one town's data to build a product for another town, and we do not use it to train models shared across customers unless that municipality asks us to in writing.
Much of the underlying model comes from public datasets published by USGS, FEMA, NLCD, state transportation departments and, in Massachusetts, MassGIS. Those are public records and are not personal information. Street, building and boundary geometry comes from OpenStreetMap, used under the Open Database License and attributed on the pages that display it.
Sensitive infrastructure. Water main, storm drain and sewer locations are treated as sensitive by many municipalities. We do not publish them, we serve them only to authenticated users scoped to that municipality, and we will follow any restriction the town places on them.
7. How we protect information
FOGLE maintains a written information security program covering the personal information we hold, as required of anyone holding personal information about Massachusetts residents under 201 CMR 17.00. In practice that means:
- Everything is served over HTTPS only. Requests on HTTP are redirected, and HTTP Strict Transport Security is set so a browser will not try plain HTTP again.
- Data is encrypted in transit with TLS and at rest by our database and storage providers.
- Every database table denies access by default. A signed in user can read and write only their own rows; a signed out visitor can read nothing at all. This is enforced by the database, not by the website, so a flaw in the website cannot reach another account's data.
- The demo form can write a request and cannot read any request back, including its own.
- Model files are held in private storage with no public object access, reachable only through short lived signed links issued to an authenticated session scoped to that municipality.
- Passwords are stored only as salted hashes by our authentication provider, and never by us.
- Access to production systems is limited to those who need it, requires multi factor authentication, and is logged.
- The browser is constrained by a Content Security Policy, so the page can load code and connect only to the small list of origins named above.
- Security relevant changes are reviewed before release, and dependencies are kept to a deliberately short list so that list can actually be watched.
No system is perfectly secure, and we will not claim otherwise. What we commit to is the list above, and to telling you promptly if it fails.
To report a vulnerability, write to Fogle.HQ@gmail.com with the subject line Security. We will acknowledge within two business days. We will not pursue legal action against anyone who reports a genuine issue in good faith, gives us reasonable time to fix it, and does not access or alter data beyond what is needed to demonstrate the problem.
8. How long we keep it
| What | Kept for |
|---|---|
| Demo requests that do not become customers | 24 months from last contact, then deleted |
| Server and platform logs | 30 days, then deleted |
| Measurement data | Aggregate only, 24 months |
| Account and municipal data | The life of the contract, then deleted within 60 days of termination, or returned in a standard format if the municipality asks |
| Correspondence | 24 months, unless it forms part of a contract record |
| Contract and billing records | As long as tax and records law requires |
9. Your rights, and how to delete your data
Whatever jurisdiction you are in, you may ask us to:
- Tell you what we hold. We will send a copy of the personal information we hold about you.
- Correct it. We will fix anything inaccurate.
- Delete it. We will erase it, subject only to records we are legally required to keep.
- Export it. We will provide it in a machine readable format.
- Object or restrict. You may object to processing based on our legitimate interest.
- Withdraw consent. Decline measurement at any time by clearing this site's storage in your browser, which brings the banner back.
We will not treat you differently for exercising any of these. No degraded service, no different price.
Deleting your account yourself
If you have an account, open your workspace, scroll to Your account, and choose Delete my account and data. This removes your profile, your saved models and your answers immediately and cannot be undone.
Asking us to delete it
- Write to Fogle.HQ@gmail.com from the address you used with us, with the subject line Privacy request.
- Tell us your name and the town or city you wrote from, so we can find the record. We will not ask you for more information than we need to verify you, and we will never ask for a government identifier.
- We will acknowledge within 10 business days and complete the request within 45 days. If it is genuinely complex we may take a further 45 days, and we will tell you why before we do.
- We will write back confirming what was deleted, and naming anything we had to keep, with the reason.
If you are an authorised user of a municipal account, your municipality controls that account. Ask your administrator to remove your access, or write to us and we will coordinate with them.
You may use an authorised agent to make a request on your behalf where state law allows it. We will ask for written proof of their authority.
10. State specific rights
Several US states give residents specific privacy rights. Some of those laws apply only to businesses above a size threshold, and FOGLE may sit below the threshold in a given state. We would rather honour the rights than argue about thresholds, so we extend the following to everyone who asks, regardless of where they live.
- The right to know what we collect, why, and who we disclose it to.
- The right to a copy, and to have it corrected or deleted.
- The right to opt out of sale, of sharing for cross context behavioural advertising, and of profiling with legal or similarly significant effects. We do none of these three, so there is nothing to opt out of, and we will confirm that in writing if you ask.
- The right not to be discriminated against for exercising any of them.
- The right to appeal a refused request. Reply to our decision and a different person will review it and respond within 45 days, with reasons.
California residents. We do not sell or share personal information as those terms are defined by the California Consumer Privacy Act as amended, and we have not done so in the preceding twelve months. We do not collect sensitive personal information as defined by that Act. The categories we collect are set out in section 2 above, and our purposes in section 3.
Massachusetts residents. Massachusetts does not currently have a general consumer privacy statute, but it does regulate the safeguarding of personal information under 201 CMR 17.00 and breach notification under M.G.L. c. 93H. Our security program under those rules is described in section 7, and what happens after a breach is in section 11. Nothing in this policy limits your rights under M.G.L. c. 93A.
11. If something goes wrong
If personal information we hold is acquired or used by an unauthorised person, we will:
- Investigate immediately and contain it.
- Notify affected people and the appropriate regulators as soon as practicable and without unreasonable delay, following Massachusetts M.G.L. c. 93H and the breach notification law of any other state whose residents are affected.
- For Massachusetts residents, notify the Office of Consumer Affairs and Business Regulation and the Attorney General as that law requires, and tell you what we are doing about it.
- Tell any affected municipality directly, in addition to any individual notice.
- Our notice will describe what happened and what you can do. As Massachusetts law requires, it will not describe the nature of the breach or the number of residents affected in the notice sent to you.
12. Cookies and measurement
This site sets no cookies in order to function as a public website. Signing in sets a session cookie, which is strictly necessary to keep you signed in and cannot be declined while you are signed in. Nothing is loaded for measurement until you press accept.
| What | Type | Purpose | Lifetime |
|---|---|---|---|
| fogle.theme | Local storage | Remembers light or dark appearance | Until you clear site data |
| fogle.consent | Local storage | Remembers your answer to the banner | Until you clear site data |
| fogle.attribution | Session storage | Campaign parameters for this visit | Until you close the tab |
| fogle.guestModel | Local storage | Your answers if you use the town picker without an account | Until you clear site data |
| Supabase auth session | Cookie and local storage | Keeps you signed in | Until you sign out or it expires |
| Plausible Analytics | Script, no cookie | Counts page views and product events | Not applicable |
We honour Global Privacy Control. If your browser sends that signal, measurement stays off without your having to touch the banner.
Measurement is off for this browser.
13. Public records and municipal customers
Our customers are public bodies, and records they hold are often subject to the Massachusetts Public Records Law, M.G.L. c. 66, or the equivalent in another state. We will not stand in the way of a municipality meeting an obligation under that law, and we will help it respond.
Where a municipality asks, we will provide the model version, inputs and source layers behind a result so it can be explained on the public record.
Some infrastructure records may be exempt from public disclosure on security grounds. Deciding that is the municipality's call, not ours, and we will follow its determination.
14. Children
This site and this product are for municipal staff. We do not knowingly collect personal information from anyone under 16. If you believe a child has sent us personal information, write to Fogle.HQ@gmail.com and we will delete it.
15. Changes to this policy
When this policy changes we update the date at the top. For a change that affects how we use your personal information, we will email account holders at least 14 days before it takes effect, and keep the previous version available on request.