Privacy Policy

Humtap Privacy Policy

Last updated: January 18, 2021.

If you are a user and your usual residence is in the US, this Privacy Policy shall apply.

If you are a user and your usual residence is in the EEA and Switzerland, this Privacy Policy shall apply.

If you are a user and your usual residence is not in the US, EEA or Switzerland, this Privacy Policy shall apply. There may also be jurisdiction-specific provisions for certain countries or regions.

Privacy Policy

(If you are a user and your usual residence is in the US)

Welcome to Melody (the “Platform”). The Platform is provided and controlled by Humtap Inc. (“Humtap”, “we” or “us”). We are committed to protecting and respecting your privacy. This Privacy Policy covers the experience we provide for users age 13 and over on our Platform.

Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

What information do we collect?

We collect information when you create an account and use the Platform. We also collect information you share with us from certain third-parties, and technical and behavioral information about your use of the Platform. We also collect information contained in the messages you send through our Platform and information from your Contacts, if you grant us access to your phone book on your mobile device. More information about the categories and sources of information is provided below.

Information you choose to provide

For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

registration information, such as age, username and password, language, and email or phone number;
profile information, such as name and profile image;
user-generated content, including comments, photographs, audio and video files that you choose to upload or broadcast on the Platform (“User Content”);
your phone and social network contacts, with your permission. If you choose to find other users through your phone Contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform;
your opt-in choices and communication preferences;
information to verify an account;
information in correspondence you send to us;
information you share through surveys such as your gender, age, likeness, and preferences; and
information we obtain from other sources.

We may receive the information described in this Privacy Policy from other sources, such as:

Third-Party Services. We may collect information about you from third-party services, such as data analytics providers.
Others Users of the Platform. Sometimes other users of the Platform may provide us information about you, including through customer service inquiries.
Other Sources. We may collect information about you from other publicly-available sources.

Information we collect automatically

We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your IP address, geolocation-related data (as described below), unique device identifiers, browsing and search history (including content you have viewed in the Platform), and Cookies (as defined below).

Usage Information

We collect information regarding your use of the Platform and any other User Content that you generate through and broadcast on our Platform. We also link your subscriber information with your activity on our Platform across all your devices using your email, phone number, or similar information.

Device Information

We collect information about the device you use to access the Platform, including your IP address, unique device identifiers, model of your device, your mobile carrier, time zone setting, screen resolution, operating system, app and file names and types, keystroke patterns or rhythms, and platform.

Location data

We collect information about your location, including location information based on your SIM card and/or IP address. With your permission, we may also collect Global Positioning System (GPS) data.

Messages

We collect and process, which includes scanning and analyzing, information you provide in the context of composing, sending, or receiving messages through the Platform’s messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants of the communication. Please be aware that messages sent to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or disclose messages.

Metadata

When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content, the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account. Additionally, metadata will consist of data that you chose to provide with your User Content.

We and our service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) automatically to collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, and improve the Platform. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. To learn how to disable Cookies, see your “Your choices” section below.

Additionally, we may allow these service providers to collect information about your online activities through Cookies. We and our service providers link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. We are not responsible for the privacy practices of these service providers, and the information practices of these service providers are not covered by this Privacy Policy.

We may aggregate or de-identify the information described above. Aggregated or de-identified data are not subject to this Privacy Policy.

How we use your information

As explained below, we use your information to fulfill and enforce our Terms of Service, to improve and administer the Platform, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions and promote the Platform.

We generally use the information we collect:

to fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback;
to customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen, or show you content that is similar to content that you like or interacted with;
to improve and develop our Platform and conduct product development;
to support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform;
to use User Content as part of our advertising and marketing campaigns to promote the Platform;
to understand how you use the Platform, including across your devices;
to infer additional information about you, such as your age, gender, and interests;
to help us detect abuse, fraud, and illegal activity on the Platform;
to ensure that you are old enough to use the Platform (as required by law);
to communicate with you, including to notify you about changes in our services;
to enforce our terms, conditions, and policies;
consistent with your permissions, to provide you with location-based services, such as personalized content;
to inform our algorithms;
to combine all the information we collect or receive about you for any of the foregoing purposes; and
for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

How we share your information

We are committed to maintaining your trust, and while Humtap does not sell personal information to third parties, we want you to understand when and with whom we may share the information we collect for business purposes.

Service Providers

We share the categories of personal information listed above with service providers to help us perform business operations and for business purposes, including research, database maintenance, technology services, deliveries, email deployment, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing. These service providers may include:

customer and technical support providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically;
researchers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically but would not receive message data;
cloud-based data storage providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically; and
marketing and analytics vendors, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically but would not receive your payment information or message data.

Within Our Corporate Group

We may share all of the information we collect with a parent, subsidiary, or other affiliate of our corporate group.

In Connection with a Sale, Merger, or Other Business Transfer

We may share all of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy.

For Legal Reasons

We may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security to Humtap Inc., the Platform, our affiliates, users, or the public. We may also share any of the information we collect to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law.

With Your Consent

We may share your information for other purposes pursuant to your consent or with your further direction.

If you choose to engage in public activities on the Platform, you should be aware that any information you share may be read, collected, or used by other users. You should use caution in disclosing personal information while using the Platform. We are not responsible for the information you choose to submit.

Your Rights

You may submit a request to access or delete the information we have collected about you by sending your request to us at the email or physical address provided in the Contact section at the bottom of this policy. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account. We do not discriminate based on the exercise of any privacy rights that you might have.

Your Choices

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, our choice to disable cookies is specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you. Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.

You can switch off GPS location information functionality on your mobile device if you do not wish to share GPS information.

If you have registered for an account you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

The Platform is not directed at children under the age of 13. If we become aware that personal information has been collected on the Platform from a person under the age of 13, we will delete this information and terminate the person’s account. If you believe that we have collected information from a child under the age of 13 on the Platform, contact us at: julian@humtap.com.

Other Rights

Sharing for Direct Marketing Purposes (Shine the Light)

If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To submit a request, contact us at: julian@humtap.com.

Content Removal for Users Under 18

Users of the Platform who are California residents and are under 18 years of age may request and obtain removal of User Content they posted by contacting us at: julian@humtap.com. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the user Content you want removed and information reasonably sufficient to permit us to locate that User Content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

Contact

Please address any questions, comments and requests regarding this policy to:

Mailing Address: Humtap Inc., Attn: 545 San Antonio Road, #315, Mountain View, CA 94040, USA
Email: julian@humtap.com

Privacy Policy

(If you are a user and your usual residence is in the European Economic Area (EEA) or the UK, or Switzerland)

Last updated: January 18, 2021

Welcome to Melody (the “Platform”). We are committed to protecting and respecting your privacy, and this policy sets out the basis on which we process any personal data we collect from you, or that you provide to us. Where we refer to “Humtap”, “we” or “us” in this Privacy Policy, we mean Humtap Inc. (“Humtap”).

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and use the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and use the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. In order to provide an effective and dynamic Platform, and where we have determined it is in our legitimate interests, we use your information to improve and develop the Platform, prevent crime and ensure users’ safety. Where we have your consent, we will also use your personal data to promote the Platform.

With whom do we share your information?

We share your data with third-party service providers who help us to deliver the Platform, including cloud-based data storage providers. We also share your information with business partners, other companies in the same group as Humtap, and data analytics providers. We may share your information with law enforcement agencies, public authorities or with other third parties only where we are legally required to do so or if such use is reasonably necessary (for instance, to ensure your or someone else’s safety).

Your Rights

We offer you settings to control and manage the personal data we have about you. You also have the following rights: you can ask us to delete your data; to change or correct your data; to provide a copy of your data and to stop using some or all of your data. You can contact us using the contact information below, and we will review your request in accordance with applicable laws.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for legal claims.

How will we notify you of any changes to this Privacy Policy?

We will notify all users of any material changes to this policy through a notice on our Platform or by other means. We update the “Last Updated” date at the top of this policy, which reflects the effective date of the policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

1. The types of personal data we use

We collect and use the following information about you:

your Profile Information: you give us information when you register on the Platform, including your username, date of birth, email address and/or telephone number, information you disclose in your user profile and your photograph or profile video;
User Content and Behavioural Information: We process the content you generate and view on the Platform, including preferences you set (such as choice of language), photographs, audio files and videos you upload, comments and live-streams you make (“User Content”). We collect information through surveys in which you participate. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how often you use the Platform and how you interact with content we show you, audio and video content you interact with and problems encountered, the content you like, the content you save to “Favourites”, the words you search and the users you follow.
We infer your interests, gender and age for the purpose of personalising content.
We review User Content for content moderation purposes to enforce our community guidelines, comply with legal obligations, and prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform.
We also process information about your followers, the likes you receive and responses to content you upload, for the purposes of personalising your Feed, promoting your content to other users and exploring whether your profile presents opportunities for collaboration.

Messages

Where local laws allow us to, we collect and process your messages, which includes scanning and analysing the information in those messages through the Platform’s messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants in the communication.

We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people.

Please also be aware that messages sent to other users of the Platform will be accessible by those users, and that we are not responsible for how those users use or disclose them.

Information from Third Parties

You may choose to share certain data with us from third parties or, through your use of the Platform, we may collect such third party data automatically.

For more information about how our measurement and analytics providers collect data from the Platform, please see our Cookies Policy.

Technical Information we collect about you

We collect certain information from you when you use the Platform including when you are using the app without an account. Such information includes your IP address, instance IDs (which allow us to determine which devices to deliver messages to), mobile carrier, time zone settings, identifier and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location

When you use the Platform on a mobile device, we will collect information about your location in order to customise your experience. We infer your approximate location based on your IP address. In certain jurisdictions, we may also collect Global Positioning System data.

Information about your friends

You can choose whether to invite your contacts to join you on the Platform. We will use the contact information you have for that person, and give you the option to invite them to view your Humtap profile.

We use your personal data to find matches based on your contact information and your address book. However, your contact information and your address book is private and will not be disclosed. We use a technical system to find matches without sending your own information or your address book to us in plain text.

Information you provide to us

We collect information you provide us in response to a survey. If you respond to a Humtap survey, your individual responses will be used for the purpose of the survey and will be shared with other organisations, as explained to you when you participate in a survey. We may also use aggregate data from these surveys in a similar way.

We also collect information you provide to us in correspondence.

2. Cookies

Cookies and similar technologies (e.g., pixels and ad tags) (collectively, “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including personal data, from you in order to provide certain features and functionality. We and our service providers use Cookies to collect data and recognise you and your device(s) on the Platform and elsewhere across your different devices. We do this to enhance your user experience.

3. How we use your personal data

We will use the information we collect about you based on the legal grounds described below.

In accordance with, and to perform our contract with you, we will use your information to:

provide the Platform and associated services;
notify you about changes to our service;
provide you with user support;
enforce our terms, conditions and policies;
administer the Platform including troubleshooting;
personalise the content you receive and provide you with tailored content that will be of interest to you;
enable you to share User Content and interact with other users;
enable our messenger service to function if you choose to use it and are 16 or above;
enable you to participate in the virtual items program; and
communicate with you.

In order to comply with our legal obligations and as necessary to perform tasks in the public interest or to protect the vital interests of our users and other people, we use your data to help us prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform.

In accordance with our legitimate interests to provide an effective and dynamic Platform, we may use your information to:

ensure your safety and security, including reviewing User Content, messages and associated metadata for breaches of our Community Guidelines and our Terms of Service;
ensure content is presented in the most effective manner for you and your device;
understand how people use the Platform so that we can improve, promote and develop it;
promote popular topics, hashtags and campaigns on the Platform;
carry out data analysis and test the Platform to ensure its stability and security;
verify your identity and your age, for example, to ensure you are old enough to use certain features;
inform our algorithms so we can deliver the most relevant content to you and to prevent crime and misuse of the Platform;
carry out surveys regarding our services, products and features;
allow you to participate in interactive features of the Platform; and
enable you to socialise on the Platform.

Where we process your information to fulfill our legitimate interests, we conduct a balancing test to check that our use of your personal data is really necessary for us to achieve our business purpose. When we carry out this balancing test we also take into account the privacy rights of our users and put in place appropriate safeguards to protect their personal data.

4. How we share your personal data

We share your data with the following selected third parties:

Analytics and measurement providers

We use analytics and measurement providers to help us improve the Platform including by assisting us with content measurement and following your activity on our Platform across your devices.

Our Corporate Group

We may share your information with other members, subsidiaries, or affiliates of our corporate group where it is necessary to provide the Platform in accordance with the Terms of Service.

We share information to improve and optimise the Platform, including to prevent illegal use and to support users.

Law Enforcement / Legal Obligation

We may share your information with law enforcement agencies, public authorities or other third parties if we consider that we are legally required to do so or if such use is reasonably necessary to:

comply with a legal process or request;
enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation;
detect, prevent or otherwise address abuse, fraud, illegal activity or security or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Profiles

Your content will be visible to anyone on the Platform, and may also be accessed or shared by your friends and followers, as well as third parties such as search engines, content aggregators and news sites. Other users can use your content to produce and upload further content.

Sale or Merger

We disclose your information to third parties:

in the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we will disclose your data to the prospective seller or buyer of such business or assets; or
if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where we store your personal data

The personal data that we collect from you will be transferred to, and stored at, a destination outside of the European Economic Area ("EEA").

Where we transfer your personal data to countries outside the EEA, we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to Commission Decision 2004/915/EC or 2010/87/EU (as appropriate) or in line with any replacement mechanism approved under EU law.

6. Your Rights

We offer you settings to control and manage the personal data we have about you.

You have the following rights:

Access Your Data: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.
Delete Your Data: You can ask us to delete all or some of your personal data.
Change or Correct Data: You can ask us to change or fix your data. You can also make changes using the in-app controls and settings.
Portability: You can ask for a copy of personal data you provided in a machine readable form.
Object or Restrict Use of Data and Withdraw Consent: You can ask us to stop using some or all of your data, e.g., if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes; withdraw your consent or ask us to stop making any automatic individual decisions, including profiling. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

For information about how to make these requests, you can contact us using the contact information below, and we will review your request while considering applicable laws.

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform, which means any transmission is at your own risk.

We have appropriate technical and organisational measures to ensure a level of security appropriate to the risk that may be posed to you and other users. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

We may, from time to time, include links to and from 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 these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data.

If you ask us to delete your account it will first be placed into a deactivated state for 30 days (to allow you to request it to be reinstated), followed by the deletion of the account. We will also delete personal data that relate to the in-app messaging function within 30 days of you cancelling your user account. Please note that messages sent to other users of our service are stored on their devices and cannot be deleted by us.

In each case, there are also occasions where we may need to keep your data for longer in accordance with our legal obligations or where it is necessary for legal claims.

9. Information relating to children

Humtap is not directed at children under the age of 13. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: julian@humtap.com.

10. Changes

We will notify you of any material changes to this policy through a notice provided via the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.

11. Who we are and how to contact us

Humtap provides the Platform and associated services, and processes personal data in the manner described in this policy and in our Terms of Service.

If you have questions or complaints regarding this policy, or if you wish to reach the Humtap’s Data Protection Officer, contact us at: julian@humtap.com. You can also contact us at the following postal address: Humtap Inc., 545 San Antonio Road, #315, Mountain View, CA 94040, USA.

If contacting us does not resolve your complaint, you have the right to complain to your local data protection supervisory authority.

Privacy Policy

(If you are a user and your usual residence is not in the US, EEA or Switzerland)

Last updated: January 18, 2021

Welcome to Melody (the “Platform”). The Platform is provided and controlled by Humtap Inc. (“Humtap”, “we” or “us”).

We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

If you have any questions about how we use your personal data, contact us at: julian@humtap.com.

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and interact with the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. We use your information to, among other things, show you suggestions, improve and develop the Platform and ensure your safety.

With whom do we share your information?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with other companies in the same group as Humtap, measurement providers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally-binding court order.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data, or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe they are or will be necessary for the establishment, exercise or defence of legal claims.

How will we notify you of any changes to this Privacy Policy?

You should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process them.

1. The types of personal data we use

We collect and use the following information about you:

Your Profile Information. You give us information when you register on the Platform, including your username, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video.
User Content and Behavioural Information. We process the content you generate and view on the Platform, including preferences you set (such as choice of language), photographs, audio and video files you upload, comments and live-streams you make (“User Content”). In order to improve the upload speed of User Content before clicking “Post” to confirm the upload, we will provide a preload service to upload audio and video in advance. If you cancel or fail to upload the content for other reasons, we will delete the associated audio and video from our server. We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, videos you watch and problems encountered, the content you like, the content you save and the users you follow. We also infer your preferences, including your interests, gender and age for the purpose of personalising content. We process information about your followers, the likes you receive and responses to content you upload, for the purposes of promoting your content to other users and exploring whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this information to tell you about new services and opportunities.
Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically.
Technical Information we collect about you. We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes your IP address, browsing history (i.e., the content you have viewed on the Platform), mobile carrier, time zone settings, identifier and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system. Where you login from multiple devices, we will be able to use your profile information to identify your activity across devices.
Location. We use the 'Region' you select in Settings to customise your Humtap experience except where we provide location-based services, in which case we collect GPS (where we have your consent).

2. Cookies

We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, and improve our services. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

Additionally, we allow our service providers (including analytics vendors) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

3. How we use your personal data

We will use the information we collect about you in the following ways:

notify you about changes to our service;
provide you with user support;
personalise the content you receive and provide you with tailored content that will be of interest to you;
enable you to share User Content and interact with other users;
enable our messenger service to function if you choose to use this function;
communicate with you;
to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;
ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
ensure content is presented in the most effective manner for you and your device;
improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform;
carry out data analysis and test the Platform to ensure its stability and security;
allow you to participate in interactive features of the Platform;
to ensure that you are old enough to use our Platform (as required by law).
provide you with location-based services (where those services are available in your jurisdiction);
enforce our terms, conditions and policies; and
administer the Platform including troubleshooting.

4. How we share your personal data

We share your data with the following selected third parties:

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Data Analytics providers

We use data analytics providers to help us in the optimisation and improvement of the Platform.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

comply with legal obligation, process or request;
enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Profiles

Sale or Merger

We will also disclose your information to third parties:

in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where we store your personal data

The personal data we collect from you may be stored on a server located in the United States. We may also maintain servers elsewhere to bring you our services globally and continuously.

6. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We may, from time to time, include links to and from 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 these policies. Please check these policies before you submit any information to these websites.

7. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

8. Information relating to children

Humtap is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements, please see your local privacy policy for more information. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: julian@humtap.com.

9. Complaints

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: julian@humtap.com. We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

10. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

11. Contact

If you have questions, comments, or requests regarding this policy, contact us at: julian@humtap.com.