Effective Date: February 22, 2019
Click on the links below to jump to each section:
• Information We Collect
• How We Use Your Information
• How We Share Your Information
• Control Over Your Information
• Third Party Tracking and Online Advertising
• Data Retention
• Confidentiality and Security
• Children’s Privacy
• Links to Other Websites and Services
• Your California Privacy Rights
• How to Contact Us
1. INFORMATION WE COLLECT
The categories of information we collect can include:
• Information you provide to us directly. We may collect personal information, such as your name, phone number, location, payment information, and email address when you use or register for our Service.
• Creating Accounts. When you create an account through our StayTouch service, you need to provide us with your name, mobile number, email, and a password. If you subscribe to our StayTouch Premium Service, you will need to provide us with payment information such as your credit card number and billing address. Your account information is not visible to your contacts.
• Creating Profiles. When you create a profile, you have full control over the information included in the profile such as your photo, education, work experience, skills, or contact information (e.g. email, phone number, or mailing address) or links to social media accounts. If you upload a photo, we may request access to the camera roll and camera on your mobile device. You may withdraw this permission to access your device’s camera roll and camera at any time through the ‘Settings’ in your mobile device’s app. Your profile information is different from your StayTouch account information, and is only visible to people who have added you as a contact through StayTouch (unless you declined their request to share your contact info) or who you shared your profile information through email or your phone’s native sms text messaging app.
If you subscribe to the StayTouch Premium Service, you are able to create multiple profiles with the same or different information. You are the master of your contact information and can choose what information to include in each profile.
Please note that we do not require you to include sensitive information in your profiles such as date of birth, race, ethnicity, biometrics, medical information, financial information or social security number. Please do not include sensitive information in your profiles. If you choose to include such information, it will be visible to those with whom you have shared your profile as described above.
Communications with us. We receive your information such as name, email address, or phone number when you sign up for our mailing list, fill out a survey, or otherwise communicate with us. We may also collect any communications between you and us, and any other information you provide to us.
• Voice Notes. With your permission, we collect voice notes and request access to the microphone on your mobile device in order to facilitate the voice notes for StayTouch. You may withdraw this permission to access your device’s microphone at any time through the ‘Settings’ in your mobile device’s app. Voice notes are for individual use and should not be used to record others. We are not responsible for the recording of any third parties through the use of voice notes. On that end, if you will use voice notes, you agree to comply with all applicable laws, whether federal, state, local or international, relating to the privacy of communications, including advising all participants in a recorded conversation that the conversation is being recorded and obtaining their consent, as required.
• Address Book and Calendar Information. With your permission, we may request access to your contacts or calendar information available on your mobile device or through your email accounts and import or sync contact and calendar information with StayTouch. On that end, we may also receive your personal information when others import or sync their contacts or calendar with StayTouch. You can turn off syncing at any time. You choose who to invite or send your vCard. If you choose to send invitations via text message, standard rates may apply. When inviting your contacts to connect via StayTouch, we use third-party service providers to facilitate sending your emails or texts. Please note that you are the sender of these messages. Only send invitations to contacts you know personally.
• Information from Other Sources. We may receive information about you from third parties and combine this information with other information we collect from or about you. For example, we may receive your information when someone uploads to StayTouch your contact information that is stored on their phone or address book. We may also receive your information from third parties such as distribution partners, data services, and marketing firms.
For more information about your communication preferences, see “Control Over Your Information” below.
We, and our third-party partners, automatically collect certain types of usage information when you visit our Sites, use or Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
• Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our Service, for example, the site from which you came and the site to which you are going when you leave our Service, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, whether you accepted a contact, and other actions you take on the Service.
• Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps
• We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
Cookies Opt Out. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Do Not Track Signals. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
3. HOW WE USE YOUR INFORMATION
We may use your information for the following purposes:
• To update your in-app contacts with the latest profile information, enable you to send your vCard and invite others to join the Service and connect with you, and take advantage of StayTouch features such as connection analytics (e.g. how many times you’ve met with a person, extent of meetings), or meeting reminder.
• To operate, maintain, improve, and provide to you the features and functionality of the Service, including the StayTouch Premium Service.
• To communicate directly with you, such as to send you Service-related emails and push notifications (e.g., account verification, updates to features of the Service, technical and security notices). We may also send you promotional messages, including email messages and push notifications, from us and from our partners. You may change your communications preferences at any time, see the “Control Over Your Information” section below. Please note that you are not able to opt-out of receiving service messages from us, including security and legal notices.
• To remember your information so you will not have to re-enter it during a subsequent visit; help you efficiently access your information after you sign in; provide, improve, test, update and monitor the Service; or diagnose or fix technology problems.
• To identify potential customers who are using our services for the purposes of targeting relevant marketing to such persons.
• To enable you to participate in interactive features of the Service (such as engaging in surveys or promotions).
• To comply and fulfill our legal duties and obligations such as tax and accounting.
• To ensure the security of our products and services and preventing abuses.
• To ensure the security of our IT environments and protection of data.
• To respond to your emails, comments, questions or requests for customer service.
• For any other purpose we may describe when you provide the information.
4. HOW WE SHARE YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We may share your personal information with:
• Third parties at your request. For example, you may share your contact information with others through email, or text, or you may want to invite others to join the Service and add you as a contact. Third parties will only see your name (and Company name if you have provided one), until they accept you as a contact. You will only see a third party’s name (and third party’s company name if they have entered one), until you accept them as a contact. Once the connection is made, a third party will be able to see the information you include in your profile. Please do not include in your profile personal information you would not want to be shared. If you subscribe to our StayTouch Premium Service, you may be able to create multiple profiles. Only the information included in the specific profile shared with a contact will be visible. For example, if you have a “painter” profile and a “writer” profile through your StayTouch Premium Service, and you share your “writer” profile with a contact, that contact will only see the information included in the “writer” profile, and not the “painter” profile. You are in full control of the profiles you create, and the profiles you share with your contacts (number of profiles depends on whether you have the StayTouch Basic or Premium Service).
• Other companies and brands owned or controlled by Company, and other companies owned by or under common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy;
• Third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes;
• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services;
• The public when you provide feedback on our Service. For example, if you post user content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages;
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings;
• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Company, our visitors, or others.
• We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
5. CONTROL OVER YOUR INFORMATION
Profile and Data Sharing Settings. You may update your profile information, such as your company name, job title and profile photo etc. by editing information on your user profile(s) screen(s) and may change some of your data sharing preferences on your Settings page or by emailing us at firstname.lastname@example.org.
Access to Your Device Information. You may control the app’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the app to access your address book, location, photo stream, and camera.
How to Control Your Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences on your Settings page, by clicking on send notifications tabs on screens such as favorites in your StayTouch contact book, or by emailing us at email@example.com.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances.
6. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
Social Media Advertising. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.
• Cookies and Flash cookies. As noted above, most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.
Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by clicking here. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.
• Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices.
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
7. DATA RETENTION
We may retain your information as long as appropriate for business purposes, unless we are required by law or regulation or for litigation and regulatory investigations to keep it for longer periods of time. Any personal information that we have acquired, either directly or from third parties, and that is no longer needed for any business or record-keeping purposes, is disposed of securely and in compliance with established best practices for secure data destruction and/or deidentification.
8. CONFIDENTIALITY AND SECURITY
We maintain commercially reasonable physical, electronic, and procedural safeguards designed to protect the information. These safeguards include storing your information on our secure servers behind firewalls. Despite the actions and precautions, we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of the information and you acknowledge and agree that you transmit it to us at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
9. CHILDREN’S PRIVACY
We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at email@example.com.
10. LINKS TO OTHER WEB SITES AND SERVICES
The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
11. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of the third parties to which we have disclosed “personal information” (as that term is defined under applicable California law) for such third parties’ direct marketing purposes. We do not currently share personal information with third parties for their own direct marketing purposes.
12. HOW TO CONTACT US