Thank you for choosing to be part of our community atPOPARAZZI by TTYL Inc. ("Company", "we", "us", or"our"). We are committed to protecting your personal information andyour right to privacy. If you have any questions or concerns about our policy,or our practices with regards to your personal information, please contact usat hello@poparazzi.com. When you visit our mobile application, and use ourservices, you trust us with your personal information. We take your privacyvery seriously. In this privacy policy, we seek to explain to you in theclearest way possible what information we collect, how we use it and whatrights you have in relation to it. We hope you take some time to read throughit carefully, as it is important. If there are any terms in this privacy policythat you do not agree with, please discontinue use of our Apps and ourservices. This privacy policy applies to all information collected through ourmobile application, ("Apps"), and/or any related services, sales,marketing or events (we refer to them collectively in this privacy policy asthe "Services").
Please read this privacy policy carefully as it will helpyou make informed decisions about sharing your personal information with us.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. WHAT ARE YOUR PRIVACY RIGHTS?
7. DATA BREACH
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS LINKSTO THIRD PARTY WEBSITES
11. CHILDREN’S PRIVACY
12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WECOLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provideto us such as name, address, contact information, passwords and security data,and payment information. We collect personal information that you voluntarilyprovide to us when registering at the Apps, expressing an interest in obtaininginformation about us or our products and services, when participating inactivities on the Apps (such as posting messages in our online forums orentering competitions, contests or giveaways) or otherwise contacting us.
The personal information that we collect depends on thecontext of your interactions with us and the Apps, the choices you make and theproducts and features you use. The personal information we collect can includethe following:
Personal Information Provided by You. We will collect information that you elect toprovide to us while using the Apps. Specifically, if you elect to invite yourfriends to join our online community the Apps will access the contactinformation associated with your friend including their name, mobile phonenumber and email address. Refer to our Terms of Service for additional details.
Photos. You may usethe Apps to post photographs to the social profiles of other users. Those photos may contain your personalinformation, such as full-face images or other personal information that may becaptured in the photo.
Credentials. We collect passwords, password hints, andsimilar security information used for authentication and account access.
All personal information that you provide to us must betrue, complete and accurate, and you must notify us of any changes to suchpersonal information.
Information automatically collected
In Short: Some information - such as IP address and/orbrowser and device characteristics - is collected automatically when you visitour Apps.
We automatically collect certain information when you visit,use or navigate the Apps. This information does not reveal your specificidentity (like your name or contact information) but may include device andusage information, such as your IP address, browser and device characteristics,operating system, language preferences, referring URLs, device name, country,location, information about how and when you use our Apps and other technicalinformation. This information is primarily needed to maintain the security andoperation of our Apps, and for our internal analytics and reporting purposes.
Online Identifiers. We collect devices; tools and protocols,such as IP (Internet Protocol) addresses; cookie identifiers, or others such asthe ones used for analytics and marketing; device's geolocation; and othersimilar data.
Information collected through our Apps
In Short: We may collect information regarding yourgeo-location, mobile device, push notifications, when you use our apps.
If you use our Apps, we may also collect the followinginformation:
· Geo-Location Information. We may request accessor permission to and track location-based information from your mobile device,either continuously or while you are using our mobile application, to providelocation-based services. If you wish to change our access or permissions, youmay do so in your device's settings.
· Mobile Device Access. We may request access orpermission to certain features from your mobile device, including your mobiledevice's camera, microphone, contacts, storage, notifications, sensors, andother features. If you wish to change our access or permissions, you may do soin your device's settings.
· Mobile Device Data. We may automatically collectdevice information (such as your mobile device ID, model and manufacturer),operating system, version information and IP address.
· Push Notifications. We may request to send youpush notifications regarding your account or the mobile application. If youwish to opt-out from receiving these types of communications, you may turn themoff in your device's settings.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based onlegitimate business interests, the fulfillment of our contract with you,compliance with our legal obligations, and/or your consent.
We use personal information collected via our Apps for avariety of business purposes described below. We process your personalinformation for these purposes in reliance on our legitimate businessinterests, in order to enter into or perform a contract with you, with yourconsent, and/or for compliance with our legal obligations. We indicate thespecific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
· To facilitate account creation and logonprocess. If you choose to link your account with us to a third party account(such as your Google or Facebook account), we use the information you allowedus to collect from those third parties to facilitate account creation and logonprocess for the performance of the contract.
· To send administrative information to you. Wemay use your personal information to send you product, service and new featureinformation and/or information about changes to our terms, conditions, andpolicies.
· Request Feedback. We may use your information torequest feedback and to contact you about your use of our Apps.
· To invite your friends to join the community. Ifyou elect to do so, we will use contact information you have stored in your contactsabout your friends in order to invite them to download the Apps. Specifically,we will use your friends name, email address and mobile phone number. Refer toour Terms of Service for additional details.
· To enable user-to-user communications. We may useyour information in order to enable user-to-user communications with eachuser's consent. For example, we offer privatemessaging and group chats among persons associated with a photo.
· To enforce our terms, conditions and policiesfor Business Purposes, Legal Reasons and Contractual.
· To respond to legal requests and prevent harm.If we receive a subpoena or other legal request, we may need to inspect thedata we hold to determine how to respond.
· To manage user accounts. We may use yourinformation for the purposes of managing our account and keeping it in workingorder.
· To deliver services to the user. We may use yourinformation to provide you with the requested service.
· To respond to user inquiries/offer support tousers. We may use your information to respond to your inquiries and solve anypotential issues you might have with the use of our Services.
· For other Business Purposes. We may use yourinformation for other Business Purposes, such as data analysis, identifyingusage trends, determining the effectiveness of our promotional campaigns and toevaluate and improve our Apps, products, marketing and your experience. We mayuse and store this information in aggregated and anonymized form so that it isnot associated with individual end users and does not include personalinformation. We will not use identifiable personal information without yourconsent.
We will only use your personal information when the lawallows us to. Most commonly, we will use your Personal Information in the followingcircumstances:
· Where we need to perform the contract we areabout to enter into or have entered into with you.
· Where it is necessary for our legitimateinterests (or those of a third party) and your interests and fundamental rightsdo not override those interests.
· Where we need to comply with a legal obligation.
Note that we may process your personal information for morethan one lawful ground depending on the specific purpose for which we are usingyour data.
If you are based outside the United States, please note thatthe personal information that you provide through the App is transferred to theUnited States (where privacy laws may not be as adequate as in yourjurisdiction) to Company and third parties engaged by Company to assist in operationof the App or provide a service to you. By using the App, you expressly agree to the transfer of the personalinformation to the United States.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, tocomply with laws, to provide you with services, to protect your rights, or tofulfill business obligations. We may process or share data based on thefollowing legal basis.
· To Third Parties Assisting in Our Operations.Company may share your Personal Information under confidentiality agreementswith other companies that work with, or on behalf of, Company to provideproducts and services, such as a cloud hosting company or identity verificationservice. These companies may use your personal Information to assist Company inits operations. However, these companies do not have any independent right toshare this information.
· Consent: We may process your data if you havegiven us specific consent to use your personal information in a specificpurpose.
· Legitimate Interests: We may process your datawhen it is reasonably necessary to achieve our legitimate business interests.
· Performance of a Contract: Where we have enteredinto a contract with you, we may process your personal information to fulfillthe terms of our contract.
· Legal Obligations: We may provide informationabout you to respond to subpoenas, court orders, legal process or governmentalregulations, or to establish or exercise our legal rights or defend againstlegal claims. We believe it is necessary to share information in order toinvestigate, prevent or take action regarding illegal activities, suspectedfraud, situations involving potential threats to the physical safety of anyperson, or as otherwise required by law. In such circumstances, we will takeappropriate measures to ensure that the requester understands the sensitivenature of the Personal Information that they may receive.
· Vital Interests: We may disclose yourinformation where we believe it is necessary to investigate, prevent, or takeaction regarding potential violations of our policies, suspected fraud,situations involving potential threats to the safety of any person and illegalactivities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or shareyour personal information in the following situations:
Business Transfers. We may share or transfer yourinformation in connection with, or during negotiations of, any merger, sale ofcompany assets, financing, or acquisition of all or a portion of our businessto another company. We will require anysuch successor business entity to honor the terms of this Privacy Policy.
Third-Party Advertisers. We may use third-party advertisingcompanies to serve ads when you visit the Apps. These companies may useinformation about your visits to our Website(s) and other websites that arecontained in web cookies and other tracking technologies in order to provideadvertisements about goods and services of interest to you.
Other Users. When you share personal information (forexample, by posting comments, contributions or other content to the Apps) orotherwise interact with public areas of the Apps, such personal information maybe viewed by all users and may be publicly distributed outside the Apps inperpetuity. Similarly, other users will be able to view descriptions of youractivity, communicate with you within our Apps, and view your profile.
Offer Wall. Our Apps may display a third-party hosted"offer wall." Such an offer wall allows third-party advertisers tooffer virtual currency, gifts, or other items to users in return for acceptanceand completion of an advertisement offer. Such an offer wall may appear in ourmobile application and be displayed to you based on certain data, such as yourgeographic area or demographic information. When you click on an offer wall,you will leave our mobile application. A unique identifier, such as your userID, will be shared with the offer wall provider in order to prevent fraud and properlycredit your account.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessaryto fulfill the purposes outlined in this privacy policy unless otherwiserequired by law.
We will only keep your personal information for as long asit is necessary for the purposes set out in this privacy policy, unless alonger retention period is required or permitted by law (such as tax,accounting or other legal requirements). No purpose in this policy will requireus keeping your personal information for longer than the period of time inwhich users have an account with us.
When we have no ongoing legitimate business need to processyour personal information, we will either delete or anonymize it, or, if thisis not possible (for example, because your personal information has been storedin backup archives), then we will securely store your personal information andisolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal informationthrough a system of organizational and technical security measures.
We use appropriate security measures preventing yourPersonal Information from being accidentally lost, used or accessed in an unauthorizedway, altered or disclosed. However, please also remember that we cannotguarantee that the internet itself is 100% secure. Although we will do our bestto protect your personal information, transmission of personal information toand from our Apps is at your own risk. You should only access the Serviceswithin a secure environment.
6. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European EconomicArea, you have rights that allow you greater access to and control over yourpersonal information. You may review, change, or terminate your account at anytime.
In some regions (like the European Economic Area), you havecertain rights under applicable data protection laws. These may include theright (i) to request access and obtain a copy of your personal information,(ii) to request rectification or erasure; (iii) to restrict the processing ofyour personal information; and (iv) if applicable, to data portability. Incertain circumstances, you may also have the right to object to the processingof your personal information. To make such a request, please use the contactdetails provided below. We will consider and act upon any request in accordancewith applicable data protection laws.
If we are relying on your consent to process your personalinformation, you have the right to withdraw your consent at any time. Pleasenote however that this will not affect the lawfulness of the processing beforeits withdrawal.
If you are resident in the European Economic Area and youbelieve we are unlawfully processing your personal information, you also havethe right to complain to your local data protection supervisory authority. Youcan find their contact details here:http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights,you may email us at hello@poparazzi.com.
Account Information
If you would at any time like to review or change theinformation in your account or terminate your account, you can:
· Log into your account settings and update youruser account.
Upon your request to terminate your account, we willdeactivate or delete your account and information from our active databases.However, some information may be retained in our files to prevent fraud,troubleshoot problems, assist with any investigations, enforce our Terms of Useand/or comply with legal requirements.
Opting out of email marketing: You can unsubscribe from ourmarketing email list at any time by clicking on the unsubscribe link in theemails that we send or by contacting us using the details provided below. Youwill then be removed from the marketing email list - however, we will stillneed to send you service-related emails that are necessary for theadministration and use of your account. To otherwise opt-out, you may:
· Access your account settings and updatepreferences.
· Note your preferences when you register anaccount with the site.
7. DATA BREACH
A privacy breach occurs when there is unauthorized access toor collection, use, disclosure or disposal of personal information. You will benotified about data breaches when TTYL Inc. believes you are likely to be atrisk or serious harm. For example, a data breach may be likely to result inserious financial harm or harm to your mental or physical well-being. In theevent that TTYL Inc. becomes aware of a security breach which has resulted ormay result in unauthorized access, use or disclosure of personal informationTTYL Inc. will promptly investigate the matter and notify the applicableSupervisory Authority not later than 72 hours after having become aware of it,unless the personal data breach is unlikely to result in a risk to the rightsand freedoms of natural persons.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems andmobile applications include a Do-Not-Track ("DNT") feature or settingyou can activate to signal your privacy preference not to have data about youronline browsing activities monitored and collected. No uniform technologystandard for recognizing and implementing DNT signals has been finalized. Assuch, we do not currently respond to DNT browser signals or any other mechanismthat automatically communicates your choice not to be tracked online. If a standardfor online tracking is adopted that we must follow in the future, we willinform you about that practice in a revised version of this privacy policy.
9. CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of California, you aregranted specific rights regarding your personal information.
If you are a California resident, California law providesyou with the following rights with respect to your personal information:
· The right to know what personal information we havecollected, used, disclosed and sold about you during the preceding 12 months,as described above in the Section “What Information Do We Collect?” To submit arequest to know, visit poparazzi.com. You also may designate an authorizedagent to make a request for access on your behalf on our website atpoparazzi.com.
· The right to request that we delete any personalinformation we have collected about you. To submit a request for deletion,visit this link. You also may designate an authorized agent to make a requestfor deletion on your behalf on our website at poparazzi.com.
When you exercise these rights and submit a request to us,we will verify your identity by asking you to log in to your account if youhave one with us. If you do not have anaccount with us, we may ask for additional information to verify youridentity. We also may use a third partyverification provider to verify your identity.
Your exercise of these rights will have no adverse effect onthe price and quality of our goods or services.
10. LINKS TO THIRD PARTY WEBSITES
As a convenience to our users, the Apps and Services maycontain links to other websites that we believe may offer useful information.As stated in more detail in the Terms of Service, the terms of usage and otherconditions of use posted on those sites, and not the policies and procedures wedescribed here, apply to those sites. Your linking to any other websites is atyour own risk, and you are responsible for learning about and complying withthe terms of usage and other conditions posted on those websites.
11. CHILDREN’S PRIVACY
Under Age 13
We understand the importance of protecting children'sprivacy in the interactive online world. The Apps and the Services are notdesigned for, or intentionally targeted at, children under 13 years of age. Itis not our policy to intentionally collect or maintain information about anyoneunder the age of 13. No one under theage of 13 should submit any Personal Information to Company, the Apps or theServices.
Under Age 18
Minors under 18 years of age may have the personalinformation that they have provided to Company through the Website deleted byvisiting this link. Please note that,while we make reasonable efforts to comply with such requests, deletion of yourpersonal information does not ensure complete and comprehensive removal of thatdata from all systems.
12. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary tostay compliant with relevant laws.
We may update this privacy policy from time to time. Theupdated version will be indicated by an updated "Revised" date andthe updated version will be effective as soon as it is accessible. If we makematerial changes to this privacy policy, we may notify you either byprominently posting a notice of such changes or by directly sending you anotification. We encourage you to review this privacy policy frequently to beinformed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you mayemail us at hello@poparazzi.com or by post to:
TTYL Inc.
1046 Princeton Dr., Unit #108
Marina Del Rey, CA 90292
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WECOLLECT FROM YOU?
Based on the laws of some countries, you may have the rightto request access to the personal information we collect from you, change thatinformation, or delete it in some circumstances. To request to review, update,or delete your personal information, please submit a request form by clickinghere. We will respond to your request within 30 days.