Legal and Regulatory Compliance
SUMMARY
This Legal and Regulatory Due Diligence Statement is provided by Feature, Inc. (“Feature.io”) to support partner and client evaluations of the Feature platform. Feature.io operates Smart Content™, an enterprise SaaS infrastructure layer that enables partners to deliver non-financial digital goods and utility items to users based on real-time engagement. The platform does not issue, store, or enable the transfer of cryptocurrency, monetary value, or any asset subject to financial regulation. Feature.io may issue partner-provided discount codes or promotional items, all of which are standard marketing incentives and not financial instruments.
Feature.io acts solely as a data processor on behalf of its partners. The platform does not collect or process sensitive personal information, financial data, or biometric identifiers. The company maintains compliance with applicable global privacy regulations and employs enterprise-grade data security practices. Feature.io has no regulatory, licensing, or statutory restrictions that would impair its ability to deliver its services to enterprise partners.
1. Company Overview
Feature.io provides Smart Content™, an enterprise SaaS platform that enables partners to deliver digital utility items upon user engagement. These items may include artwork, access badges, personalized digital objects, or partner-provided discount codes. These items do not possess monetary value and are non-transferable, non-exchangeable, and not redeemable for cash.
Feature deploys an internal identity and asset container system (“wallets”) solely for the purpose of storing earned items. These internal wallets are not financial wallets, are not blockchain wallets, and do not trigger any financial regulatory framework. They serve a similar function to in-app inventories or loyalty containers found in consumer applications.
Feature.io is not engaged in activities involving securities, cryptocurrency, gambling, money transmission, or any regulated financial service.
2. Regulatory Status
2.1 Non-Applicability of Financial Regulations
Feature.io does not issue or facilitate digital payment tokens, virtual currencies, stablecoins, or any instrument subject to the jurisdiction of the SEC, CFTC, FINRA, FinCEN, MAS, FCA, or any equivalent regulatory bodies. The platform does not:
- Enable the sale, purchase, transfer, or exchange of digital assets
- Hold customer funds or stored monetary value
- Provide custodial services
- Facilitate any form of secondary market
- Enable speculation or investment-related activity
Because Feature’s internal wallets function solely as repositories for non-financial digital items, Feature.io is not classified as a money services business, electronic money issuer, payment service provider, or digital asset operator in any jurisdiction.
2.2 Promotional Codes and Consumer Incentives
Feature.io may deliver partner-provided discount codes or access codes. These are standard promotional incentives and are not equivalent to stored-value products, gift cards, cash equivalents, or financial instruments. They do not trigger financial regulatory oversight.
3. Data Privacy and Personal Information Compliance
Feature.io complies with global data protection frameworks, including:
- California Consumer Privacy Act (CCPA/CPRA)
- EU General Data Protection Regulation (GDPR)
3.1 Categories of Personal Information Collected
Feature may process the following non-sensitive personal information:
- Email address or partner-provided account identifier
- Engagement activity and event completion metadata
- Device-level identifiers, including IP address
- Non-identifying session and usage information
Feature does not collect or process:
- Financial data
- Biometric data
- Medical or health information
- Government-issued identifiers
- Sensitive or special-category personal data
3.2 Purpose of Processing
Personal information is processed exclusively to:
- Verify user engagement or content completion
- Deliver digital items via Feature’s internal wallet system
- Support analytics and reporting requested by partners
Feature does not use personal information for advertising, resale, profiling unrelated to engagement, or any independent commercial purpose.
3.3 Data Processor Role
Feature acts solely as a Data Processor/Service Provider.
Partners act as Data Controllers and define the scope, purpose, and lawful basis of processing.
3.4 Retention and Deletion
Feature retains personal data only for the duration necessary to support partner programs and deletes or anonymizes data upon partner request or based on contractual retention periods.
4. Data Security
Feature.io maintains enterprise-grade data security practices, including:
- Encryption in transit (TLS 1.2+)
- Encryption at rest (AES-256)
- Multi-factor authentication for administrative accounts
- Principle of least privilege and role-based access
- Continuous logging and monitoring
- Regular vulnerability testing and system hardening
4.1 Cloud Infrastructure
Feature.io is hosted on Google Cloud, inheriting SOC 2 Type II and ISO 27001 aligned infrastructure controls. Region-specific hosting can be provided as required by partners.
5. Intellectual Property and Brand Compliance
Feature.io complies with all partner-specific intellectual property, branding, and content usage requirements. Feature does not publicly use partner trademarks, logos, or identifiers without prior written approval. All digital items incorporating or referencing partner IP shall adhere to partner brand guidelines and approval processes.
6. Consumer Protection and Advertising
All digital goods, rewards, and incentives delivered via Smart Content are free to earn and not based on chance. Feature.io does not operate sweepstakes, lotteries, gambling mechanics, or pay-to-play systems.
Discount codes and promotional incentives comply with applicable consumer protection standards and do not create financial or regulatory exposure.
7. Cross-Border Data Transfers
Feature.io supports compliant international data transfer mechanisms, including EU SCCs and adherence to regional privacy laws in applicable markets.
Cross-border data transfers occur only in accordance with partner instructions and contractual data-processing agreements.
8. Limitations or Regulatory Restrictions
Feature.io has no regulatory limitations that would impair its ability to provide its platform or services. The platform operates solely within standard enterprise SaaS regulatory boundaries and does not involve regulated financial systems, clinical or biometric data, or data relating specifically to minors.
9. Legal Entity and Ownership
- Legal Entity: Feature, Inc. (Feature.io)
- Product: Smart Content™
Feature.io has no outstanding litigation, regulatory enforcement actions, or compliance violations.
Ownership and corporate structure information can be provided upon request for due diligence purposes.
10. Summary Statement
Feature.io’s Smart Content™ platform is not subject to specialized financial, digital asset, or payment-service regulation. The platform’s regulatory considerations are limited to data privacy compliance, IT security, consumer promotional rules, and intellectual property governance as defined by partner engagements. Feature.io is fully capable of operating within enterprise environments without regulatory or statutory impediments.