1. WHAT INFORMATION WE COLLECT
Information We Collect About You through the Services:
When you use the Services, we may collect information about you, including:
- Registration details you provide when you create an account, such as your e-mail address, telephone number, username, and password.
- Facebook profile information, such as name and email address, if you choose to log in to the Services through Facebook.
- Personal information you provide when you use the Services, including information you provide when you access or use the Services and each time you interact with the Services or otherwise with us, for example, when you update your personal information in your app, communicate with us by telephone or e-mail, and order or download updates.
- Device information such as operating system version, device type, and system performance data.
- Information you provide in public forums through the Services, including using our chat, review, comment, post or similar functionality.
- Information we receive about you from third parties (e.g., if you access the Services through a third-party platform or log-in), we may also collect your e-mail address and other information associated with that third party, and any information you have made public in connection with that service or which the third party shares with partner services). See also Section 7 (“Third Party Websites and Links”) below.
- We do not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to purchases made through the Apple App Store and Google Play Store.
Cookies and Similar Technology:
We also use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Services. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve the Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
“Do Not Track” is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At this time, we do not recognize Do Not Track signals.
2. HOW WE USE YOUR INFORMATION
The ways in which we may use your information include the following:
- To provide you with the Services and other services you request.
- To save your account, registration, and profile information so that you do not need to re-enter it every time you use the Services.
- To answer your questions or requests for information.
- To administer your account.
- To communicate with you about your account or transactions with us and send you details or updates about features of the Services or changes to our policies.
- To create anonymized and aggregated data sets that may be used for a variety of functions, including research, internal analysis, analytics, and other functions.
- To detect, investigate and prevent activities that may violate our policies or be illegal.
- To personalize and improve the Services and user experiences.
- To send you offers and promotions for our other products and services.
- To (i) provide you with news and updates about the Company; or (ii) send you surveys to collect feedback about your experience with the Company, in order to improve the Services. You are permitted to opt out of any such communications at any time.
3. HOW WE SHARE YOUR INFORMATION
We may share your personal information outside Oye under limited circumstances, including but not limited to:
- When you request our referral services to forward or share certain content with a friend, such as an e-mail inviting a friend to use the Services or sharing certain content from the Services with a friend.
- When we contract or partner with a third party to provide services on our behalf, for example, with companies who provide us with certain administrative services, as well as other partners who assist us in carrying out, developing and maintaining the Services.
- In connection with the sale of a business, including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings.
- To enforce our Terms of Service or rules, to ensure the safety and security of our users and third parties.
- To protect our rights and property and the rights and property of our users and third parties.
- To comply with legal process, including judicial warrant, rule, order or subpoena or in other cases if we believe in good faith that disclosure is required by law or regulation.
In addition, we may share anonymized and aggregated data sets with third parties, alone or in combination with anonymized information of other users.
4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you no longer wish to receive these communications, you may either click “unsubscribe” at the bottom of these communications or email us at email@example.com, and we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Services, you will receive these SMS messages. Standard text message rates will apply.
We will honor valid requests to opt out of receiving communications as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Services (such as notifications about updates to our Terms of Service).
5. YOUR RIGHTS
Depending on where you are located or reside, you may have the right to exercise certain controls and choices regarding our collection, use and sharing of your personal information, including your right to:
- Know what types of personal information we collect from you and how we may share it;
- Correct inaccurate personal information we may have of yours;
- Delete your personal information (under certain circumstances);
- Obtain a portable copy of the personal information we process (under certain circumstances);
- Opt out of the sale or sharing of your personal information;
- Limit our use or disclosure of any sensitive personal information (as defined under California law) that we may collect.
You may exercise these rights, as applicable, by contacting us at firstname.lastname@example.org or following the instructions provided in communications sent to you. Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain services to you, and some of our Services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact us at email@example.com.
6. THIRD PARTY WEBSITES AND LINKS
Our Services may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your personal information. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. Please keep in mind that personal information you post on public or semi-public venues, including personal information you share on third party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. When you provide personal information to a third-party online platform, the personal information you provide may be separately collected by that third-party. The personal information the third-party online platform collects is subject to the third-party online platform’s privacy practices. Privacy choices you make on the third-party online platform will not apply to our use of the information we collect directly through our Services.We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties.
7. CHILDREN’S PRIVACY
Our Services are not directed to children who are under 18 years of age, or the age of legal majority in your jurisdiction, and we do not seek or knowingly collect any personal information from them without obtaining consent from the child’s parent or guardian. If we become aware that we have unknowingly collected personal information from a child under 13 years of age without such consent, we will make commercially reasonable efforts to delete such information from our database.If you are the parent or guardian of a child under 13 years of age who has provided us with personal information, you may contact us at firstname.lastname@example.org to request it be deleted.
8. SECURITY AND DATA RETENTION
Please note that Information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use insecure channels to communicate sensitive or confidential personal information to us. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.
We will retain your personal information for as long as needed to fulfill the purpose for which it was originally provided to us, or if we have another valid legal basis to retain it, including but not limited to, establishing, exercising, or defending legal claims; our legitimate business interests; or as otherwise provided or required by law.
9. EU/EEA/UK Privacy Rights
If you are located in the European Union, the European Economic Area, or the United Kingdom, this Policy is supplemented by our “Additional Privacy Statement for EU, EEA and UK Users” section which explains your privacy rights and how you can exercise these rights (among other matters).
11. HOW TO CONTACT US
Any questions or concerns regarding the use or disclosure of personal information should be directed to email@example.com.
Last updated April 2023
Additional Privacy Statement for EU, EEA and UK Users
Purpose and legal basis for processing
- With your consent. At times, we ask for your consent to use your personal information in a certain way and will only do so if you agree. Examples of occasions when we rely on consent include when sending you electronic marketing communications such as text or e-mail or when holding sensitive personal information about you. Whenever we use your information for a purpose based on consent, you have the right to withdraw your consent for us to use your information for this purpose at any time (as described in “your privacy rights” below).
- As necessary to perform our agreement with you, including when you agree to our Terms of Service.
- As necessary to comply with our legal obligations.For example, in some cases we may need to share your information with regulators, law enforcement agencies, public authorities, or any other relevant organizations in response to a legal obligation.
- As necessary for the establishment, exercise or defense of legal claims.
- As necessary to protect the vital interests of an individual.
- As necessary for our legitimate interests, such as to provide you with the Services. In certain cases, we collect and use your personal information on the basis of our “legitimate interests” provided our use is reasonable and does not unduly impact on your rights. We consider our legitimate interests to include all of the day-to-day activities we carry out in our effort to help you better work through your feelings, emotions and thoughts in a way that is both healthy and productive.
Some examples where we rely on legitimate interests are:
- Measuring how our audiences respond to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective; and
- Monitoring individuals’ use of our website or apps for technical, quality and improvement purposes.
Your privacy rights
If you are based in the EU, EEA, or UK for the purpose of the EU and UK General Data Protection Regulation, in certain circumstances, you have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws.
- Right not to provide consent or to withdraw consent. We may seek to rely on your consent to process certain personal data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
- Right of access and/or portability. You may have the right to access the personal data that we hold about you and, in some limited circumstances, have that data provided to you in a format that allows you to provide or “port” that data to another provider.
- Right of erasure. In certain circumstances, you may have the right to erase any personal data that we hold about you .
- Right to object to processing. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications.
- Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal data.
- Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
- Right to lodge a complaint to your local Data Protection Authority. You have the right to complain to your applicable data protection authority about our collection and use of your personal data.
How to Exercise Your Rights
To exercise the rights above, please email us at firstname.lastname@example.org.
Please identify yourself and specify your request. If you have a password protected Oye account, we may use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal data.
If you are a resident of the EU, EEA or UK, and your personal data is transferred outside of the EU, EEA or the UK, as applicable, we transfer this data where this is necessary to perform our contract with you in order to provide the Services or where you consent.
Where we transfer personal data to third parties outside of the EU, EEA or the UK, we also rely on the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), or any equivalent contracts issued by the relevant competent authority of the EU, EEA or the UK, as applicable, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities to provide an adequate level of protection for individuals’ rights and freedoms with respect to their personal data.
We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Services. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve the Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.