PRIVACY POLICY

Introduction

This Privacy Policy applies to the personal information we process in the context of the operation of our video communication service Join ("Service") and is incorporated into and is subject to our Terms of Service. Please find below a summary of the key topics addressed in this Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not use the Service and must immediately terminate your use of the Service.

 

 

PRIVACY POLICY

 

Effective Date: March 1, 2023

1. Personal Information We Collect

When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual. The following types of personal information are collected in connection with our Service:

Information You Provide Directly to Us or we receive from Third Parties

We may collect information directly from you or from other companies with whom you have a relationship. For example:

 When you create an account and register for our Service, you provide us with information such as, your email address, date of birth, gender, mobile phone number.

 When you login with a third party account, we receive information about you from third parties including from other companies such as Facebook or Google. For example, we will get access to information such as your social media account information, nickname, email address, date of birth, gender, profile information and your friend list (depending on your choices).

 If you choose to, additional information that you can add to your profile, such as a bio, links to your social media accounts.

 When you start using the Service, we collect user-generated contents, including comments, short messages, photos, voice and videos calls (including captured picture thereof), that you choose to share, transmit, broadcast and/or upload on our      Service.

 When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.

 When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.

 When you win a prize from a promotional event, or when you decide to participate in our rewards programs, you will provide us with information such as, a copy of identification card, your name, account information.

 If you contact us (e.g., through our customer care team), we collect the information you give us during the interaction.

 Users may provide information about you as they use our Services, for instance as they interact with you or if they submit a report involving you.

Information about Your Use of Our Service

In addition to the information you provide, we will collect information about your use of our Service through software on your devices and by other electronic means, including by the use of cookies.

This includes:

 Device information: OS platform of your device, device information including type of device, brand, model and version of OS, IP address, advertising identifier, device language, device timezone, version of application that you are using, locale country and language of the device, the location (country and city) where you log in, your purchase history in application store, available languages, device capability, bandwidth, network type, and traffic to and from our websites, error-reporting information, the time the error occurred, the feature being used and the state of the Application when the error occurred.

 Log information: Usage information, such as, URL, redirected URL,      performance timing, referrer, network type, network info, charge status, ad block info, cookies, access and reports history.

 Location information: We will process your location or geographical information based on your consent or if permitted, where this is necessary to deliver the Service you have requested.

 Service usage information: Service use history, Service activity history, gifting history, purchases, consumption and refund history, details of your interactions with other users including following or followed history, details of interaction between you and the Service or you and our website including report history, time broadcasted or time spent watching broadcasting on our Service, and other information about your use of our Service, such as bookmarks and visit history.

 

Links to Other Websites, Devices, Apps and Features

Our Service may enable you to connect to other websites, devices, apps and other features, which may operate independently from us and have their own privacy notices or policies. If you accessed a website, product or service provided by a third party, including through the Service or Company's website, such third party may also collect information about you. Please see the privacy policies of each such third party for more information about how they use the information they collect. This Privacy Policy does not apply to any exchange of information between you and any third party.

 

2. How We Use this Information

Provision of our Service based on your contractual relationship with us

We process your personal information when this is necessary under our contract with you, to:

 Provide you with our Service, and specific features you select when using our Service, which may require personalizing the content of our Service;

 When you use our live streaming feature, we use your information to broadcast the live stream on our Service, that can be viewed by other users as well as non-users on the web and on other third-party apps;      

 Process orders, payments and refunds and deliver to you our products that you purchase through our Service and allow you to exercise your rights that you have under your contract;

 Identify and authenticate you so that you may use our Service and to prevent illegal or inappropriate use of the Service;

 Restrict the collection of personal information of children under certain age as defined in this Privacy Policy;

 Deliver to you any administrative notices, alerts and communications relevant to your use of the Service;

 Effectively manage our relationship with our customers, including by communicating with you, responding and handling queries and reports, resolving technical issues, providing you with customer care support and sending you necessary information relating to our Services

Use of information for further purpose

 To improve the Service, and to develop and offer new services. We may use your information to improve the performance of or develop new services, for example, we may use de-identified conversation between you and our Join Chatbots to improve them or other chatbots we own or to build new services;

 To provide information about various events and opportunities to participate in the events, to provide advertising information;

 To contact you via email, SMS, app push notification or otherwise for the purpose of informing you about new products, services or promotions offered by the Company (you can opt-out of such emails or SMSs by sending an email to [email protected]);

 To collect statistics on the use of Service including Service usage history, access frequency and interaction between users, to analyze customer behaviors, build up customer usage patterns and profiles in order to identify regional and global user trends and optimize our offering to customers globally and to improve the Service and its environments using the statistics;

 To protect against, identify, monitor and prevent fraud and other criminal activities, any other activities that may violate our Terms of Service or other applicable laws, or lead to claims or other liabilities.

 To restrict use of Service that violates laws and our Terms of Service, to prevent use of Service that interfere with the operation of the Service, including fraudulent use, and to prevent account theft.

Other

 Comply with and enforce requirements under applicable laws, relevant industry standards and our policies, including this Privacy Policy.

 Comply with court orders and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators.

 Protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us or other companies in our group and our Service.     

 

3. Sharing of Information

We transfer or disclose your personal information to third parties as described below:

 Affiliates, subsidiaries, partners and personnel: We share your information with our personnel, including contractors and agents, and other companies, to the extent this is necessary to provide our Service and to fulfill the purposes set out in Section 2 above.

 Service providers: We also transfer or disclose your information to carefully selected companies that provide services on our behalf; for example companies that help us develop and operate systems for our Service, payment and refund service providers, providers of IT services, security, hosting, analytics, mailing, billing or marketing services. These entities are only authorized to access and use your personal information to the extent this is necessary for them to provide us with their services and they are not allowed to use this information for other purposes.

 Business advisors: We may share, for example, your information with our lawyers, accountants, business consultants, insurers, and auditors, to the extent it is necessary for them to provide us with their services.

 Government authorities, judicial authorities, regulators or other third parties where required: We will disclose personal information to government authorities, judicial authorities, regulators or other third parties where we have a legal requirement to do so or where we believe this is necessary:

 to comply with the law or respond to compulsory legal processes (such as a search warrant, subpoena or court order);

 to verify or enforce compliance with the terms and policies governing our Service and to investigate fraud or other unlawful activity relating to the use of our Service or affecting our business, to the extent such disclosure is permitted by applicable data protection laws; and

 to protect and defend our rights, property, and the security or safety of our business operations and those of any of our respective affiliates, staff, business partners, our customers or members of the public.

 Corporate transactions: We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

 Other parties with your consent or on your request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

Any information or content that you voluntarily disclose for posting to the Service ("User Contents") may become available to the public. Once you have shared User Contents or made it public, that User Contents may be re-shared by others. This Privacy Policy does not apply to such public information.

 

4. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information in accordance with the following principles:

 at least for the duration for which the information is used to provide you with our Service;

 as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or

 only for as long as it is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards. For example, if a dispute arises between you and Company or you fail to make payment for our Service, we may retain relevant information until such dispute is resolved or until such payment is made, respectively.

 Where we process your information with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of your requests in order to respect them in future.

 

5. Your Choices

Where permitted we may contact you via email, phone call, text messages or push notifications through our mobile apps.

You can unsubscribe from our marketing communications at any time by contacting us directly. As noted in the Your Rights section below, you have the right to object to use of personal data for direct marketing purposes at any time.

Please note that if you unsubscribe from our marketing communications, we will still send you service messages to provide you with necessary information in relation to your contract and the Service you use (for example, to update you on changes to our Terms of Use).

 

6. Your Rights

To the extent provided by applicable law, you can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also have the right to request that we delete personal information that we hold about you. You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.

In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.

However, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

 

7. How We Protect Personal Information

We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Service. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

Please note, however, that the Service allows you to share text messages, photos, screenshots, videos and other communications in the Service with other users, and if you choose to share these items with other Service users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages, photos, screenshots, videos or other communications in the Service is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of others with whom you have shared the information). The Service is not responsible for any use or misuse of information you share.

 

8. Personal Information of Children

The Service is not directed to children under the age of fourteen (14) and we do not knowingly solicit or collect personally identifiable information from children under the age of fourteen (14) as part of the Service. Additionally, we do not knowingly sell the personal information of children under the age of sixteen (16). If we become aware that we have inadvertently received personally identifiable information from a user under the age of fourteen (14) as part of the Service, we will immediately delete such information from our records.

 

9. Contact Us

For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact us at [email protected].

 

10. Updates to Our Privacy Policy

We reserve the right at our discretion to make changes to this Privacy Policy from time to time. We will notify you before we make changes to this Privacy Policy. You may also review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Service and our website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you may not use the Service at any time.