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UberMedia® Products Privacy Policy

Effective: January 1, 2020

This Privacy Policy describes how UberMedia, Inc. (“UberMedia” “we” or “us”) collects, stores and uses information about users of our websites (“Sites”) and mobile applications (“Apps”) owned by UberMedia, Inc. (collectively, the “Products”). By using our Products, you agree to UberMedia’s collection, storage, use and disclosure of information as described in this Privacy Policy. If you disagree with anything in this Privacy Policy, please do not install or use Our Products.

Background

Our Products support users’ experience with Twitter including the social apps, Echofon and UberSocial and Plume. To use these App, users (“Users”) need to login in using their Twitter credentials.

WHAT INFORMATION IS COLLECTED

We collect the following types of information from our Users:

  • Information You Provide: When you set up your account, provide us with an email, or share information with us in any other way, such as a customer support request, we collect and store the information you share. This will include your twitter handle, but not your password which is retained by Twitter. You do not have to share information with us, but without it you may not be able to access certain content or features of the Products.
  • Automatic Collection: Like many technology providers, we use common internet technologies such as cookies on Sites and persistent tools on Apps to keep track of users’ interactions with the Products. These tools will collect general device and browser information, including device type and model, browser type and version, app type and versions, as well as information related to your use of the Products. We also contract with third party providers who use similar tracking tags on the Products via SDKs, to collect information about your use of the Products, for advertising, analytics, and measurement purposes. More about this is discussed below.
  • Publicly Posted: If you post information on public areas via the Products (or elsewhere on the internet), that information is public and may be collected, stored and used by anyone, including us. We use a Twitter API to pull up your posts and timeline information; such information is stored by Twitter and is not stored by Us.
  • Use of Social Media Applications: The Products utilize certain API “feeds” or other mechanisms provided by third parties, notably Twitter (“Third Party Apps”), to access your accounts as authorized by you when you use of the Products. Those Third Party Apps may share information about you with us, depending upon the privacy settings you have set within your account for such Third Party Apps. The Third Party App settings enabled by you do not allow us to access content, data or information not authorized by those privacy settings. Please refer to the privacy settings in your Third Party Apps account to manage your public profile and other aspects of your account with those Third Party Apps.
  • Mobile Location Information: If you consent to allow access to your geo location on the Products, and the Products are location enabled, we will collect and store information related to your mobile device location including over time to help provide a better experience with our Products and in connection with advertising, analytics, and measurement. Some functional use of the Products may be dependent on the data related to geolocation information (such as when you post a tweet from or about a location). If the settings on your device allow us to receive location information, we may also associate location information with other information we have about you. You are always free to turn off geolocation on your device (or limit it to certain Apps).

Some of this information may identify a particular device and may be “personal information” under some jurisdictions. Personal Information, as the term used in the United States, or Personal Data as referred to pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as “GDPR”) (hereinafter “PI”) has different definitions. Different regulations around the world may use different terminology and apply a different description of what information is considered personal information, so we encourage you to visit our jurisdictional specific pages as applicable (i.e. GDPR Notice).

The information we collect from devices that may be considered PI are:

  • your Twitter handle
  • mobile advertising device ids (MAIDs): these are IDFAs for iOS, and Android Ad IDs for Android
  • Information about a User’s activities or actions on the Products and interaction with advertising that run on the Products (session start/stop time, and advertising click-stream information)
  • IP addresses and general location data that can be extrapolated from an IP address level (city or postal code)
  • Latitude and longitude geolocation information if a User has provided consent from the relevant Product and enabled the mobile device to share location information. You are always free to turn off geolocation (or limit it to certain mobile applications) or to adjust your advertising settings on your device

For clarity, and without limiting the above, we do not collect information that directly identifies a natural person, including the following information, among other information: names, email addresses, cell phone or home phone numbers, login passwords, social security, drivers licenses. We also do not collect financial or other sensitive information.

Advertising on the Products

The Products display advertisements (“Ads”) which are delivered by UberMedia’s services and through third party providers. When Ads are served, information regarding interaction with the Ads shown to you is collected by the third party advertising exchange partners and us. The Ads that are served on the Products include targeted, behavioral advertising based upon information compiled about users to provide more relevant advertising content. UberMedia and third parties operating the ad serving platforms we use, collect and utilize interest, contextual, demographic, geo-location information, and device related info (i.e. device id and browser type, date and time stamps) and information related to Ads served (such as preferences, content viewed, clicks and views) in connection with delivering and measuring advertising. This data is used to help choose which Ads to deliver and to enhance our advertising and analytics capabilities as well as to offer analytics measurement and data enhancement services to our partners for their marketing and advertising purposes. When the Products are location enabled, and you have consented to enabling access to geolocation data on the Products, UberMedia will collect and process geolocation data over time and use this data in connection with the advertising, measurement and attribution services as described herein. To the extent UberMedia makes available geolocation to third parties in accordance with this Privacy Policy, it will be provided without identifying you personally.

The Products are enabled with tools to support the services of third parties performing advertising and analytics on the Products. The third party service provider tools implemented on our Products are for the purposes of: advertising services, analytics and crash reporting services, Emoji (in UberSocial/Android and UberSocial/iPhone), Facebook to enable cross-posting and showing timelines); an Android-file logger (to allow Users to share app logs with us).To enable these services, those tools will collect and transmit devices id, device related and application related information to those providers.

HOW INFORMATION WE COLLECT IS USED

We use the information we collect for a variety of business purposes in connection with the Products, which include the following purposes:

  • Providing Our Services: Generally we use the information we collect about Users to inform about our products (including advertising) as described in this Policy and to fulfill your requests and validate your User rights; contact and communicate with you; and as otherwise described in this Policy.
  • Serving Ads: To allow Us to offer advertising inventory in the Products and to fill that inventory with relevant ads.
  • Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.
  • Service Usage and Support: To calculate usage levels, to help diagnose server problems, and administer the Products.
  • Use for Our Services Business (as described in our Business Services Privacy Policy)
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside an User’s country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside an User’s country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, Users, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

WHERE WE SHARE INFORMATION

  • Anonymous/Aggregated Information. Anonymous or aggregated information that does not identify you personally, like usage and metrics information, may be shared with others, including partners, developers, potential investors, marketers, and business partners. Anonymous information helps us understand trends and user needs so that we can better design new products and services and refine existing products and services to serve our customers better.

PI May Be Shared As Follows:

  • during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation. If UberMedia or its assets is purchased, all associated data and information will be transferred
  • with those entities who are helping us make the Services available and functional under contract and with safeguards. These include third-party vendors, technical agents, subcontractors, and our affiliates and consultants who assist us in performing functions to operate our Services. These functions include, for example, web site hosting, maintenance, data analysis, customer support, infrastructure services, technical agents, analytics and metrics services. These third parties will be contractually restricted in the way they can use PI.
  • As in any transaction, if you provide your credit card information for purchases on Product, our credit card processor and your credit card company will be provided with all relevant information about us, item(s) purchased, cost and other information necessary to process the transaction. We use a third party service provider to process payments made on our Sites, so your credit card information is not collected and retained by Us.
  • when permitted or required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users or business partners.
  • We may disclose PI to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose PI to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of PI.

WHAT ARE MY CONSUMER CHOICE/DATA PROTECTION RIGHTS/OPT OUT

For personal information access, opt out and deletion requests with respect to any PI processed by UberMedia, and for personal data of Data Subjects for residents of EU, UK and Switzerland, you can follow the instructions on our Consumer Choices page. Please note that we will need your Mobile Ad ID in order to identify your device in our systems.

While CCPA only covers California residents, We will voluntarily extend its core rights for people to control their data to all of our users across the United States, not just those who live in California.

EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE

If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see our separate section called “EU Privacy Notice – GDPR”

SECURITY

Information that UberMedia collects is stored on servers that UberMedia manages, using standard security procedures and practices appropriate to the nature of the information. Please be aware that no data transmission over the Internet or information contained in our servers can be guaranteed to be 100% secure. As a result, UberMedia cannot guarantee or warrant the security of any information you transmit on or through the Products and you do so at your own risk.

CHILDREN’S PRIVACY

The Products not intended for children under age 13 (or up to age 16 in certain countries), or for anyone under age 18 without involvement of a parent or guardian. The Products includes unmonitored content posted by users and sourced from other third parties and as you can imagine, such content may be unsuitable for children. We do not knowingly collect or distribute information from or about children under 13 (or up to age 16 in certain countries).

CHANGES TO PRIVACY POLICY

UberMedia reserves the right to change this Privacy Policy at any time, and will do so by posting changes to this Privacy Policy. The new Privacy Policy will apply to all Users of the Products and will replace any prior Privacy Policies that are inconsistent. This Privacy Policy is also subject to our Terms of Service.

DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of California applicable to agreements made and performed in California, excluding the application of the conflict of laws provisions. You agree that any action or suit brought by a party to enforce or adjudicate your rights under this Agreement shall be brought in the federal or state courts located in Los Angeles, California.

WHO WE ARE. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please email us at privacy@ubermedia.com.

Or you can contact us by mail at:

UberMedia, Inc.
130 West Union Street
Pasadena, CA 91103

Attn: Compliance Officer