|State of Indiana||Rev. 133C579|
Version Date: June 2017
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the App Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most app providers, Company gathers from users of the App Non-Personally-Identifying Information of the sort that smartphones, depending on their settings, may make available. That information includes the crash and usage information necessary for debugging failures of the app, if permission to gather such information has been granted. Although such information is not Personally-Identifying Information, it may be possible for Company to determine statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the App to help Company better understand how the App is being used. By identifying patterns and trends in usage, Company is able to better design the App to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from App users in the aggregate, such as by publishing a report on trends in the usage of the App.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the App and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the App and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
Mobile Device Additional Terms
- Mobile Device. If you use a mobile device to access the App or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
- Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
- Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company does not collect Personally-Identifying Information from within the app or its keyboard. No user input through the keyboard will be stored or transmitted to Company.
Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) purchasing the app, (2) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (3) communicating with us, or (4) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number. We also may request information about your interests and activities, your gender, age, date of birth, hometown and other demographic or relevant information as determined by Company from time to time. Users of the App are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain App features.
BY REGISTERING WITH OR USING THE APP YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
Company will disclose Personally-Identifying Information under the following circumstances:
- Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
- Third-Party Marketing Communications. Unless users opt-out from receiving marketing materials upon registration, Company may provide users’ email information to third parties, so that those third parties may directly contact them about additional products and services. To cease having your email information provided to third parties, you may do so by going to your account settings (if applicable) or contacting us using the contact information below. Even after opting-out, you may continue to receive marketing emails from third parties to whom Company already has provided your email information. You will be responsible for directly contacting such third parties to request cessation of further marketing emails.
- Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the App’s functionality and supporting contests, sweepstakes, surveys and other features offered through the App. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the App represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the App, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the App or has otherwise transferred Personally-Identifying Information to the App, please contact Company using our contact information below to have that child’s account terminated and information deleted.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.