Last Updated: June 12, 2018
1. INFORMATION WE COLLECT
In connection with your access, use, and/or registration as a User of the App, Company may collect the following information (collectively, “Information”):
- Personal Information: Information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, such as your full name, phone number, address, email address, zip code, photograph, etc. (“Personal Information”). Company typically collects some or all of this type of information as part of the Registration Data that you provide when creating your User Account.
- Payment Information: Certain payment information, such as credit card or other financial account information, as well as billing address information.
- Usage Information: Information that is not Personal Information but that relates to your usage of the App or that is necessary for the proper functioning or improvement of the App, such as the time and date and the extent of your usage of the App, the location of where you access and/or use the App, the URL, advertisement or service that referred you to the App, the search terms you entered into a search engine that led you to the App, your usage preferences, areas within the App that you access or use, how you interact with other Users (which you acknowledge that Company is under no obligation to monitor), which User’s you interact with, the mobile platform or service provider you use, your operating system, your IP address, and other unique device identifiers (“Usage Information”). Usage Information may also be collected by our third party service providers, including analytics and third party content providers.
- Other Information: Other non-Personal Information such as age, gender and other demographic data, as well as your User Account profile/label name (“Profile Name”), which Company considers to be non-Personal Information since these are made public through the App and are viewable by other Users of the App (“Other Information”). This Other Information may also be collected by our third party service providers, including analytics and third party content providers.
While Usage Information and Other Information is generally non-identifying on a standalone basis, Company may in certain instances combine this information with other information it collects, as described above. If Company ever combines Usage Information and/or Other Information with Personal Information or other information that enables you to be identified, Company will treat such combined information as Personal Information.
1. USER ACCOUNTS; PUBLIC AREAS
In order to utilize the App, you are required to create a User Account as part of the registration process, which consists of information about you, including certain Personal Information, as well as a Profile Name. Your Profile Name will be visible to all other Users of the App. You may edit certain information in your User Account via your User Account. If, in any case, you believe that an unauthorized User Account has been created about you, you can request for it to be removed by contacting us at email@example.com.
1. SOCIAL NETWORKING SERVICES
1. USE OF INFORMATION
1. DISCLOSURE OF INFORMATION
We may share aggregated Usage Information and/or Other Information and we may otherwise disclose non-Personal Information that we collect to third parties. However, except as expressly provided herein, absent your prior consent and unless necessary (as determined in Company’s sole discretion), Company does not share your Personal Information with any unrelated third parties.
Company also works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide it with information regarding traffic on the App, including pages viewed and the actions taken when visiting the App; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the App and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to, and activity on, the App as well as other websites or services, they may set and access their own tracking technologies on your device (including Cookies and Web Beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the App or other online websites and services. We may also share certain non-Personal Information with these parties, in connection with the services they provide to us.
Company also reserves the right, and you hereby authorize Company, to share or disclose Information it collects, including your Personal Information, and any other information, records or electronic communications of any kind, when Company determines, in its sole discretion, that the disclosure of such Information is necessary to identify, contact, or bring legal action against you if:
- you are interfering with Company’s or a third party’s rights or property;
- you are violating any applicable law, rule or regulation;
- necessary or required by any applicable law, rule or regulation;
- necessary or required for purposes of public importance; and/or
- requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency.
1. STORAGE AND TRANSFER OF INFORMATION
1. CHANGING, UPDATING OR DELETING INFORMATION; CLOSING YOUR ACCOUNT
1. SECURITY; HOW WE PROTECT YOUR INFORMATION
Company takes a range of security measures designed to protect your Information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, the internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete security of any Information collected, stored or used by us cannot therefore be guaranteed. We have security standards and procedures in place designed to prevent unauthorized access to your User Account and Information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. In the unlikely event that an unauthorized third party compromises Company’s security measures, Company will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately.
Should you close your Account with us and terminate your use of the App, Company will remove all of your Registration Data and Information from Company products and your Profile Name will not be available for any other Users.
We note that anyone who has access to your User Account password may be able to access your Information. Therefore, we encourage you to keep you User Account password and other User Account information contained in your Registration Data confidential. You hereby acknowledge that Company shall not be responsible or liable for any dissemination of your Information that results from your disclosure of your User Account password to any third party.
1. NEWSLETTERS; ADMINISTRATIVE AND MARKETING COMMUNICATIONS
Company maintains a strict “no-spam” policy. If you register for the App, you may receive newsletters, notices and/or special offers via email, unless you have requested otherwise at the time of registration or as set forth below. You may also receive other communications from us, such as administrative or service announcements or User Account notifications.
You may unsubscribe from electronic newsletters, notices and/or special offers at any time by following the instructions contained at the very end of every such email or text message or elsewhere as directed by Company. If a third party vendor provides such newsletters, you may unsubscribe in accordance with the instructions provided by such third party. If you are having problems unsubscribing please contact us firstname.lastname@example.org (forwarding the newsletter, if applicable, and including in the Subject line the words “Unsubscribe”), and you will be removed within seven (7) business days. Please note that Company will not process any unsubscribe requests submitted as direct replies to any newsletter.
1. COOKIES; EMBEDDED SCRIPTS
We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the App, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the App.
In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
1. LINKS TO THIRD PARTIES
1. OTHER TERMS
1. CHILDRENS’ PRIVACY
Protecting the privacy of young children is especially important. Therefore, by accessing and using the App you agree to respond truthfully and accurately about your age. In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect any personally identifiable information from children under the age of thirteen (13) (e.g., information that would allow anyone to locate children under thirteen (13) online or offline, such as full name, email address, home address, phone number, etc.). Children under the age of thirteen (13) are expressly prohibited from submitting or uploading any Information to the App. If you are under thirteen (13) years of age, then please do not use or access the App at any time or in any manner. If Company learns that Information of persons under the age of thirteen (13) years has been collected without verified parental consent, then Company will take the appropriate steps to delete this Information.
1. IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY
In the event that Company is acquired by or merged with a third party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the Information we have received and collected from our Users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.
1. SWEEPSTAKES, CONTESTS AND PROMOTIONS
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
1. Special Notice to California Residents
California Civil Code Section 1798.83 permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for direct marketing purposes in the preceding calendar year and the categories of Personal Information disclosed to those third parties. If you are a California resident, you may make such a request by contacting us at email@example.com (including in the Subject line the words “California Third Party List Request”).
1. General Data Protection Regulation (GDPR)
The General Data Protection Regulation, or GDPR, is a regulation in EU law on data protection and privacy for all individuals within the European Union and affects both European and non-European businesses alike.
Under GDPR, users are granted eight fundamental data subject rights, as follows:
- The right to be informed, in which all organizations must be completely transparent in how they use personal data.
- The data subject’s right of access, in which individuals have the right to know exactly what information is obtained about them and how it is used.
- The data subject’s right to rectification, in which individuals are entitled to have personal data rectified if it is inaccurate or incomplete.
- The right to erasure, in which an individual has the right to have their personal data deleted or removed without the need for a specific reason.
- The right to restrict processing, in which an individual has the right to block or suppress processing of their personal data.
- The right to data portability, in which individuals may retain and reuse their personal data for their own purpose.
- The right to object, in which individuals are entitled to object to their personal data being used in certain instances.
- Rights of automated decision making and profiling, in which individuals are protected against the risk of a potentially damaging decision is made without human intervention.
Full GDPR provisions, rights, principles and more can be found at https://gdpr-info.eu/
1. QUESTIONS OR CONCERNS