Last updated August 21, 2019
We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
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 DO WE HANDLE YOUR SOCIAL LOGINS?
5.IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6.HOW LONG DO WE KEEP YOUR INFORMATION?
7.HOW DO WE KEEP YOUR INFORMATION SAFE?
8.DO WE COLLECT INFORMATION FROM MINORS?
9.WHAT ARE YOUR PRIVACY RIGHTS?
12.DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13.DO WE MAKE UPDATES TO THIS POLICY?
14.HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data. We collect personal information that you voluntarily provide to us when registering at Chatio, expressing an interest in obtaining information about us or our products and services, when participating in activities on Chatio (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and Chatio, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your ﬁrst and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS " below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics
—is collected automatically when you visit Chatio. We automatically collect certain information when you visit, use or navigate Chatio. This information does not reveal your speciﬁc identity (like your name or contact information) but may include device and usage 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 Chatio and other technical information. This information is primarily needed to maintain the security and operation of Chatio, and for our internal analytics and reporting purposes.
Information collected through Chatio
In Short: We may collect information regarding your mobile device, push notiﬁcations, when you use Chatio. If you use Chatio, we may also collect the following information:
•Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
•Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
•Push Notiﬁcations. We may request to send you push notiﬁcations regarding your account or the mobile application. If you wish to
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulﬁllment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via Chatio for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the speciﬁc processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
•To facilitate account creation and logon process. 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 allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS " for further information.
•To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
•Fulﬁll and manage your orders. We may use your information to fulﬁll and manage your orders, payments, returns, and exchanges made through Chatio.
•To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
•To deliver services to the user. We may use your information to provide you with the requested service.
•For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the eﬀectiveness of our promotional campaigns and to evaluate and improve Chatio, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identiﬁable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulﬁll business obligations.
We may process or share data based on the following legal basis:
•Consent: We may process your data if you have given us speciﬁc consent to use your personal information in a speciﬁc purpose.
•Legitimate Interests: We may process your data when it is reasonably necessary to
achieve our legitimate business interests.
•Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulﬁll the terms of our contract.
•Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
•Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More speciﬁcally, we may need to process your data or share your personal information in the following situations:
•Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, ﬁnancing, or acquisition of all or a portion of our business to another company.
•Other Users. When you share personal information (for example, by posting comments, contributions or other content to Chatio) or otherwise interact with public areas of Chatio, such personal information may be viewed by all users and may be publicly distributed outside Chatio in perpetuity. If you interact with other users of Chatio and register through a social network (such as Facebook), your contacts on the social network will see your name, proﬁle photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within Chatio, and view your proﬁle.
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Chatio oﬀers you the ability to register and login using your third party social media account details (like your Facebook or
Twitter logins). Where you choose to do this, we will receive certain proﬁle information about you from your social media provider. The proﬁle Information we receive may vary depending on the social media provider concerned, but will often include your name,
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own. Our servers are located in United States. If you are accessing Chatio from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see " WILL YOUR INFORMATION BE SHARED WITH ANYONE? " above), in other countries.
In particular Company complies with the
Company is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Company is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to lawful
requests by public authorities, including to meet national security or law enforcement requirements.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from Chatio is at your own risk. You should only access the services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using Chatio, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of Chatio. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectiﬁcation or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not aﬀect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can ﬁnd their contact details here: http://ec.europa.eu/
If you would at any time like to review or change the information in your account or terminate your account, you can:
•Log into your account settings and update your user account.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we will still need to send you
•Access your account settings and update preferences.
10. DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notiﬁed about data breaches when we believe you are likely to be at risk of serious harm. For example, a data breach may be likely to result in serious ﬁnancial harm or harm to your mental or physical
11. CONTROLS FOR
Most web browsers and some mobile operating systems and mobile applications include a Do-
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Califomia, you are granted speciﬁc rights regarding access to your personal information. 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 categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal 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 us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Chatio, you have the right to request removal of unwanted data that you publicly post on Chatio. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on Chatio, but please be aware that the data may not be completely or comprehensively removed from our systems.
13. DO WE MAKE UPDATES TO THIS POLICY?
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org.