Privacy Policy

Last update: November 7, 2020.

Welcome to GotChosen (the “Platform”). The Platform is provided and controlled by GotChosen, Inc. (“GotChosen”, “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.

What information do we collect?

We collect information when you create an account and use the Platform. We collect and process information you give us when you create an account and use the Platform. This includes technical and behavioral 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 we use your information

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 serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform including cloud storage providers. We also share your information with business partners, measurement providers, advertisers and 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

You may submit a request delete the information we have collected about you by sending your request to us at the email provided in the Contact section at the bottom of this policy. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have.

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

GotChosen respects your privacy and recognize the need for appropriate protection and management of your privacy.

The Website Privacy Policy is intended to meet our duties of Transparency under the GDPR known as the “General Data Protection Regulation” and all other applicable privacy laws. We will post any modifications or changes to this Website Privacy Policy on this page.

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, name, date of birth, email address and/or telephone number, information you disclose in your user profile and your photograph.

   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 and videos you upload, comments and live-streams you make (“User Content”). 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 often you use the Platform and how you interact with content we show you, the ads you view, videos you watch and problems encountered, the content you like, the content you save, the words you search and the users you follow.

   We infer your interests, gender and age for the purpose of personalizing content. We also infer the interests of our users to better optimize advertising across our Platform. If you have consented, we will use this information for the purpose of serving personalized advertising.

   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 and reactions you receive and responses to content you upload, for the purposes of personalizing 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 analyzing 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

   We use data from GotChosen and from third-party partners, to show you ads, offers, and other sponsored content that we believe will be meaningful to you. And we try to make that content as relevant as all your other experiences on GotChosen. We also use YouTube API services to provide relevant insights to you. Check here YouTube Terms of Service, Google Privacy Policy and Google Security Settings. Understanding these terms is important because, by using these services, you’re agreeing to these terms and to be bound with YouTube Terms of Service.

   Business Partners

   If you choose to register to use the Platform using your social media account details (e.g. Facebook, Twitter, Instagram, GotChosen, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

   Advertisers and Measurement Partners

   Where you have consented to personalized advertising, we will match your information e.g. your mobile advertising ID, where it is provided to us by advertisers and other partners, with your GotChosen profile to serve you ads. We may also serve you ads based on the information we infer from the data these partners provide. You can opt out of this activity at any time via your app settings by going to 'Privacy and safety' and then to 'Personalization and data' and opting out of ‘Ads based on data received from partners’.

   We use information provided by our measurement partners, to understand how you’ve interacted with our ad partners’ websites and better assess the effectiveness of the advertising on our Platform.

   Information we obtain by automated means

   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 for advertising purposes 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.

   We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API.

   Location

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

   Information you provide to us

   We collect information you provide us in response to a survey. If you respond to a GotChosen survey, your individual responses will be used for the purpose of the survey and will be shared with other organizations, as explained to you when you participate in a survey. We may also use aggregate data from these surveys in the same 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 and business partners use Cookies to collect data and recognize you and your device(s) on the Platform and elsewhere across your different devices. We do this to better understand the effectiveness of the advertising on the Platform and 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;
   • personalize 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, for example, to enable you to have a ‘verified account’, and your age, for example, to ensure you are old enough to use certain features;
   • provide non-personalized advertising, which keeps many of our services free;
   • infer your interests for optimizing our advertising offerings, which, where you’ve consented to personalized advertising, may be based on the information our advertising partners provide to us;
   • measure the effectiveness of the advertising you see on our Platform;
   • 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 socialize on the Platform. For example, we may allow other users to identify you via the "Search" function or connect you with other users by tracking who you share links with.

   With your consent, we will use your information to provide you with personalized advertising. If you do not consent to personalized advertising, you will still see non-personalized advertising on the Platform.

4. How we share your personal data

   We share your data with the following selected third parties:

   Business Partners

   • If you choose to register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.
   • Where you opt to share content on social media platforms, the video, photo, username and any text associated with the post will be shared on that platform or, in the case of sharing via instant messaging platforms, a link to the content will be shared.

   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.

   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 third party analytics and measurement providers also help us measure advertising on our Platform and help our advertisers determine whether their advert has been shown on our Platform and how it performed. We share your mobile advertising ID and other device data with measurement companies so that they can link your activity on the Platform with your activity on our advertisers’ websites.

   Advertisers

   • We only share aggregated user information with advertisers. Aggregated information is information that is grouped together and is not specific to an individual user. This is done to help measure the effectiveness of an advertising campaign by showing advertisers how many users of the Platform have viewed or clicked on an advertisement.

   Our Corporate Organization

   • We may share your information with other members, subsidiaries, or affiliates of our corporate organization where it is necessary to provide the Platform in accordance with the Terms of Service.
   • We share information to improve and optimize 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 organizations for the purposes of fraud protection and credit risk reduction).

   Public Profiles

   • Since your profile is public, 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. If your profile is public, 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 f 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.

   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 organizational 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 organizational measures and will amend them from time to time to improve the overall security of our systems.

   We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. 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 relates 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

   GotChosen is not directed at children under the age of 13.

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. 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 terms_privacy@gotchosen.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.

Contact

Questions, comments and requests regarding this policy should be addressed to:

• Mailing Address: GotChosen Inc., Attn: GotChosen Legal Department 12472 Lake Underhill Rd, Suite 397, Orlando, Florida 32828, USA
• Contact us: terms_privacy@gotchosen.com