Last Updated: April 07, 2020
- Information We Collect and Receive
In order for Us to (i) provide You with the services and functionalities offered via the Platform, (ii) engage in troubleshooting activities, and (iii) improve upon the Platform’s performance, safety and security, We may collect and process some or all of the following types of information about You:
- Personal Information. Information that could be directly associated with you, or used to contact or identify you, including, without limitation, information you provide us when you create an Account such as your name, age, date of birth, gender, address, email address, social media login details, telephone number, photograph, and username/password, as well as certain User Content you upload to, or post on, the Platform, including, without limitation, UGC (“ Personal Information ”). As stated in our Terms of Service, while we do not actively monitor the interactions between Users of the Platform and are under no obligation to do so, we may in certain cases collect information related to your interactions with other Users of the Platform, including, without limitation, comments you make, and other User Content that that you upload to, or post on, the Platform that becomes publicly available to other Users.
- Usage Information. Information that is not Personal Information, but that relates to your usage of the Platform or that is necessary for the proper functioning or improvement of the Platform, including: (i) times and dates and the extent of your usage of the Platform; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) the User Accounts and/or User Content you view, like, comment on, share, follow, message, add memes to, and otherwise interact with, as well as the foregoing that other Users do with respect to your Account and/or User Content; (v) usage history such as areas and pages within the Platform that you access or use and/or which buttons in the Platform you click on; (vi) search terms you type in on the Platform; (vii) the URL or advertisement that may have referred you to the Platform; (viii) the mobile platform or service provider you use; and (ix) other device and Platform access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token. Only content posted or shared on the app is collected. We do not collect additional information or activities from your personal devise or store any such data.
- Behavioral Information. Your contact or subscriber information, which we link with your activity on the Platform across all your devices using your email or social media log-in details, as well as engagement scores (“likes”, comments, repeated views), related Users based on your Platform behavior, and opt-ins and communication preferences.
- Location Data. We may collect location data based on your network, not your device. Clarification: This is a very broad geo-location data which identify only city of user, needed for your analytics. We DO NOT, NOR WILL IN FUTURE, collect your geolocation based on your device, Bluetooth, access point etc, which identify a device within 2-3 feet (1-2 meters). YOUR PRIVACY IS VERY IMPORTANT FOR US.
- Messages. We may, but are not obligated to, collect and process information you provide, including any Personal Information, in the context of composing, sending, or receiving messages to other Users (that means the content as well as information about when the message has been sent, received and/or read and the participants of the communication) through our Service’s messaging functionality. Please be aware that messages sent to other users of our Service will be accessible by those other users and that we are not responsible for the manner in which those users use or disclose messages.
- Customer Support. We collect information that you provide to us, including any Personal Information, when you contact us for customer-support purposes. While certain types of information described above, such as Usage Information and Third-Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Platform, as described above. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you. YOUR PERSONAL INFORMATION IS PROTECTED
We do not collect any activity that is conducted off of the app on your personal device.
- European Union Users
European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas (“EEA”). Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“GDPR”), which are summarized below.
- Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address when you create your Account, or making certain User Content publicly available on the Platform.
- Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Platform, such as fulfilling any future subscription based, or other transactional, services.
- Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Platforms.
- Legitimate Interests: This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Platform by Users and to keep the Platform secure, (ii) may also send you promotional communications about our Platform and services subject to your right to opt-out, and (iii) analyze how Users interact with our Platform or other Users (although we are not obligated to do so) so we can understand better what elements do or do not work well, what services/functionalities may be necessary or desirable to provide you with the best User experience on the Platform, and to ensure the safety and security of the Platform, which allows us to improve and develop the quality of the online experience we offer all our Users.
- Privacy by Third-Party Platform Feature
Augmented Reality Functionality
To provide our Users with augmented reality functionality, which enable Users transform their appearance, or the appearance of certain objects, in User Content, we use object recognition software. Object recognition is an algorithm designed to help a computer generally understand what objects are in an image. Object recognition software is different than facial recognition software, and while the underlying technology object recognition can determine what is or isn’t a face, the technology does not recognize specific faces or the identity of specific individuals.
- Use of Information We Collect
We may use the information we collect about/from you to:
- Identify your account and potentially improve and/or customize the Platform;
- Send you administrative notices or Account notifications;
- Send you requested service and other Platform information;
- Address inquiries and respond to customer service requests, questions and comments;
- Administer your Account and manage your Account profile information;
- Send you newsletters and mail (including email);
- Contact you with offers, promotions and other product specials;
- Send you SMS messages (subject to certain opt-ins described herein);
- Send you more relevant marketing communications and general Platform information/updates;
- Create a more personalized User experience and customize certain content you see on the Platform;
- Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings;
- Improve your User experience and increase the efficiency and effectiveness of the Platform service and functionality offerings;
- Maintain security;
- Enforce our Terms of Service and applicable law;
- Analyze Platform usage and other trend data;
- Solicit feedback, reviews, and other information regarding your experience with the Platform, including, without limitation, with respect to certain features and functionalities that you would like to see on the Platform, or that we have recently rolled out onto the Platform;
- Test new features, service offerings and functionalities on the Platform;
- To connect to certain SM Channels and other third-party services that integrate with the Platform;
- Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection.
We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.
- Email Notifications and Opt-Out
- Sharing Your Information
Information that May be Publicly Accessible
As described in more detail in Sections 5 of the Terms of Service, certain Personal Information that you upload to the Platform (such as certain Account profile information), certain User Content (such as UGC you upload to and make public on the Platform, or comments that you post to the Platform), and certain Platform usage information (such as User Content you “like”), will automatically, or upon your selection, be made publicly available to other Users on the Platform. You acknowledge and agree that certain Account information (such as your Account profile name, picture, and/or User Content, etc.) that you provide in connection with (i) the registration of your Account and (ii) your general use of the Platform, such as uploading User Content, will be publicly viewable by all Users of the Platform. We are not responsible for the privacy practices of the other Users who will view and use this information, so you should carefully consider whether to upload any User Content on the Platform or how you identify yourself on the Platform. You should not disclose your home address or the address of your place of business, or other locations you frequent on a regular basis in any User Content.
You may share your location information with other Users. We do not share your location with other Users.
Information We May Share with Third Parties
WE DO NOT SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR ANY REASON.
Except for: Necessary or required by any applicable law, rule or regulation, including a subpoena or similar legal process or request/order; However we strongly advice legal authorities around World before issuing a subpoena. We don’t collect any private data, thus the only thing you will get, is registration form of the user. We are not under any obligation to verity authenticity of user’s information provided during registration.
Music Service Plug-ins
Company does not retain your username or password for your music services for any longer than is necessary to complete an interaction. If you would like to disconnect a music service user account from the Platform, refer to the settings of that music service account and its provider.
- Storage and Transfer of Information
- Information collected by us may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent. However, we will endeavor to take reasonable measures to keep up an adequate level of data protection also when sharing your Personal Information with such countries.
- With respect to any Personal Information that may be originally collected and stored in the EEA, if and when we transfer your Personal Information to countries outside the EEA, we will do so under the Commission’s model contracts for the transfer of Personal Information to third countries ( e. , standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact us at firstname.lastname@example.org.
- Link to Third Party Websites
The Platform may include links to other websites, mobile applications or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein. Such links are not an endorsement by Company of those Third Party Sites and/or the products or services they offer. If you visit Third Party Sites or submit Information to any of those Third Party Sites, your visit and Information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Third Party Site you visit, as it may differ substantially from that of this privacy statement. Company makes no representations or warranties with respect to, nor is Company responsible for the privacy policies of, any Third Party Sites. If you decide to click on any such links or access any Third Party Sites appearing on the Platform, you do so at your own risk.
- Your Rights
In certain circumstances you have the right to access the Personal Information that we collect/hold about you and to correct, update, or request deletion of your Personal Information. Prior to the fulfillment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request. You have the following rights:
- The right to require free of charge (i) confirmation of whether we process your Personal Information and (ii) access to a copy of the Personal Information retained;
- The right to request proper rectification, removal or restriction of your Personal Information;
- Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);
- Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
- The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
- The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.
- As far as we process your Personal Information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis in the sections above. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.
- Do Not Track Requests
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Information Relating to Children
Our Platform is not directed to children under the age of thirteen (13), and we do not knowingly collect, use, or disclose Personal Information from (i) children under the age of thirteen (13) or (ii) children between the age of 13 and 18 (or any greater age required to be deemed to have reached the age of majority under the applicable law of the state or jurisdiction of such child’s primary residence) that do not have parental or legal guardian consent to use the Platform. If we ever discover that we have inadvertently collected Personal Information from children under the age of thirteen (13) on or through the Platform, we will delete it from our records as soon as possible. If you believe that we have Personal Information about, or have collected Personal Information from, (i) a child under 13, or (ii) between the age of 13 and 18 (or any greater age required to be deemed to have reached the age of majority under the applicable law of the state or jurisdiction of such child’s primary residence) without parental/legal guardian consent, or that such a person is using the Platform, please see Section 13 of the Terms of Service for available remedies, including how to contact us to report this.
- Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions through the Platform (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.
- Contacting Us
- Your California Privacy Rights
What Information We Collect
As also detailed in the “ Information We Collect and Receive ” section above, through the Platform we collect certain Personal Information, including such information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California-resident User or his or her device. In particular, the Platform, has collected the following categories of Personal Information within the last twelve (12) months:
Category Examples Collected. Underlined are what we collect.
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||YES|
|B. Personal Information |
categories listed in the
California Customer Records statute (Cal. Civ. Code §
|A name, signature, physical |
characteristics or description, address, telephone number,
education, employment, bank account number, credit card number, debit card number, or any other financial information.
Some Personal Information included in this category may overlap with other categories.
|C. Protected classification |
California or federal law.
|Age (40 years or older), race, color, ancestry, national origin, |
citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, |
or activity patterns used to extract a template or other identifier
or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements. Partial only (City / Country.)||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or |
|Current or past job history or performance evaluations.||NO|
|J. Non-public education |
information (per the Family
Educational Rights and Privacy
Act (20 U.S.C. Section 1232g,
34 C.F.R. Part 99)).
|Education records directly related to a student maintained by an |
educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal Information does not include:
- Information publicly available from government records;
- De-identified or aggregated information from California residents; or
- Information excluded from the CCPA’s scope, including (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data and (ii) information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
How We Use Personal Information
We collect Personal Information for the business and commercial purposes described in the “Use of Information We Collect” section above. We share Personal Information with the categories of third parties described in the “Sharing Your Information” section above. We do not sell (as such term is defined in the CCPA) Personal Information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies (for WOOW website) for certain purposes as further described in the “Cookies and Other Tracking Technologies” section above.
California Residents’ Rights and Choices with Respect to Personal Information
Subject to certain limitations, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights, which specifically includes:
- Right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this information);
- Right to delete their Personal Information;
- Right to opt out of any “sales” that may be occurring; and
- Right to not be discriminated against for exercising the foregoing rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing the following: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at email@example.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an Account with us. However, we do consider requests made through your password protected Account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Company endeavors to respond to a verifiable California residents request within forty-five (45) days of its receipt. If Company requires more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Personal Information Sales Opt-Out and Opt-In Rights
We will not sell your Personal Information to any party. If in the future, we anticipate selling your Personal Information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.
Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Company will not:
- Deny you products or services on the Platform.
- Charge you different prices or rates for products or services on the Platform, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of products or services on the Platform.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of products or services on the Platform.