Privacy Policy

Privee Labs Inc. (also referred to as “we”, “our”, “us”, "Privee")  is an ad-free, subscription-based social media platform. We firmly believe that a social product without ads or tracking will provide our members with a significantly better experience.

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What information do we gather?

When you visit our Website (‘Site’) and use our App (collectively referred to as 'Services'), we collect only the information and personal data you have agreed to provide to us that is necessary to identify your needs and to provide you with better service.  Through your use of the Website, App, or registration as a new user, we may request personal data including, but not limited to:

• Name
• Contact information including email address and/or cell phone number
• Internet Protocol (“IP”) Address and other persistent identifiers
• Other information relevant to customer surveys and offers
• If you become a registered user or if you conduct transactions through our Site or App, we will collect information about the transactions you engage in while on the Site or App and other potential activities on the Site or App.  This information may include, without limitation, areas of the Site or App that you visit, transaction type, content that you view, download or submit, transaction amount, and payment, as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate.

Some of this personal data, including name, and contact information, will only be collected if you voluntarily provide it during the user registration process.

Our Website

On our website, we may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages.  We collect information that is combined with other web visitors' information, such as how many times visitors click on each web page and the methods by which our Site was found. 

We may collect IP addresses and website usage information from you when you visit our Site via the use of third party analytical providers, such as Google Analytics, and service providers, such as Viral Loops. These providers may use cookies in order to provide their services to us. An IP address is a number that is assigned to your computer when you are using your browser on the Internet.  A cookie is a small file that is stored on the hard drive of your computer ready for future access when you return to our Site.  These third party services may use cookies to keep track of your online activity.  Cookies cannot pass viruses, harm your computer or pass on private information such as an email address without the computer user's intervention.  Cookies contain session identification numbers that allow our systems to recall previous sessions for authentication efforts and assemble information from our gathered data.  You can configure your computer's browser to alert you when a site is attempting to send you a cookie and allow you to accept or refuse the cookie. Further information on how to prevent cookies from being stored on your device can be found on http://www.allaboutcookies.org under the ‘manage cookies’ section. Alternatively, you can access further information by going to the help menu within your internet browser.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To request a copy of the data you’ve submitted to the waitlist visit this Viral Loops data request link. To request deletion of the data you’ve submitted to the waitlist visit this Viral Loops deletion request link. You can opt out of these service providers at any time, but if you do, you may lose some functionality on our Site.

We use third party analytics and services to give you the best experience on our Site. 

Our Mobile App

In our app, besides account information and user generated content, analytics are collected via Heap Analytics. We collect analytics information in a pseudo-anonymized manner (linked to randomly generated user ID and a device ID) to track app interactions, usage, and feature adoption, among other performance and product metrics. We use in-app analytics to give you the best experience in-app.

For more information, you can learn about Heap’s privacy policy here.

What do we do with the personal information we collect?

You will be asked to provide personal data in certain fields on the Site and App that allow you to use our Services.  The personal data we collect is used only for the purpose we state at the time of collection or for purposes contained below.  For example, our uses may include, but are not limited to, the following:

• App functionality. We use personal data such as name, phone number, email address, for account creation and identification, linking your user-generated content to you, and to engage in interactions with you - if needed.

• To provide social networks. Some services available on the App may permit you to participate in interactive discussions, post comments, opportunities, or other content to a Forum, or otherwise engage in networking activities. Some of these services may be moderated; all may be accessed for technical reasons (for example, for improvements or fixes). We do not control the content that users post to the Forums or social networks. You should carefully consider whether you wish to submit personal information to these forums or social networks and tailor any content you submit appropriately and in accordance with the relevant terms of use. You should also review any additional terms and conditions that may govern your use of these services, including terms related to sharing your personal information and receiving communications and community guidelines.

• To assess usage of our products and services. We may track your usage of our products and services to determine your level of usage, and those usage statistics may be used to improve Site and App quality. 
• To select content, improve quality, and facilitate use of the website and app. Privee may use your personal data, including the information gathered via site and in-app analytics, to improve website and app quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of the Site and App (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security).
• To provide support or other services. We may use your personal data (e.g., email, account details) in order to provide you with support. We may also use your personal information to respond directly to your requests for information, waitlist registration, or pass your contact information to the appropriate company service providers (e.g., rewards redemption providers) to provide you support if absolutely necessary.
• To provide information based on your needs and respond to your requests. We may use your personal data to provide you with notices of new product releases and service developments.
• To update you on relevant Privee benefits, programs, and opportunities. We may communicate with you regarding relevant Privee benefits, programs, and opportunities available to you.
• To engage with third parties that provide services for Privee. We may share your personal data with third parties in connection with services that these individuals or entities perform for or with us. These third parties are restricted from using this data in any way other than to provide services for us or for the collaboration in which they and Privee are contractually engaged (for example, hosting a Privee database or engaging in data processing on our behalf, or sending you rewards you have redeemed).  We carefully select these third parties, and they are obligated to keep your data secure.
• To protect Privee content and services.  We may use your personal data to prevent potentially illegal activities and to enforce our terms of service and community guidelines.  We also use a variety of systems to detect and address anomalous activity and to screen content to prevent abuse, such as spam. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.  By using our services, you acknowledge and agree that we may access, retain and disclose the personal data we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms of Service, this Privacy Policy, Community Guidelines, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Privee, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.
• To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example through surveys, usability studies, focus groups).
• To protect Privee information assets as well as your own personal data. Our Information Security Program protects the confidentiality, integrity, and availability of our information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals.
• To assist in Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of Privee’s assets are sold or transferred to a third-party, customer personal data (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” or “pseudo-anonymize” the data, i.e., remove information that would confirm your identity.  We will not use your personal data, however, to send commercial or marketing messages to you unless we have a legal basis for doing so, such as your consent or a contract with us for which, in either case, you will have the ability to opt out of by sending an email to support@priveelabs.com.

Our services do not collect personal data when you use them unless you voluntarily and knowingly provide such information to us.  This means that we will not know your name, your email address, or any other personal data just because you browse the Site or use the App unless you: 

• access the Site or App from a link in an email or text message that we have sent to you;
• have created a profile in-app and are logged-in to your account.

In these cases we will know who you are based on the information you previously supplied to us.  When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header.  We collect the HTTP request header information in order to make our Site functions correctly and provide you with the functionality that you expect to see. We also use this information to better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personally identifiable information for an unrelated activity (e.g. highlighting your content in an advertisement), we will first request your consent to do so.

When you use our app, our analytics suite captures your in-app activity and associates with a randomly generated user ID number and device ID. Those identifiers are persistent and unique to your device, but are not tied to your personal identity in any way.

Who can use the information we collect and how?

We may provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested (e.g., they may utilize your email to send you the gift card you have redeemed your in-app rewards for). Other than those who act on our behalf and except as explained in this Policy, personal data you provide on our Site or App will not be transferred to unrelated third parties, unless we have a legal basis to do so. However, please note that personal data provided to Privee is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.

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How do we protect the personal information we collect?

Security of Personal Data

We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.  We take our security obligations seriously and so should you.  While we are responsible for maintaining the security of our Site and App, you must also access and use our Site and App in a manner that is responsible and secure.  We adhere to internationally recognized security standards. In addition, we have implemented a series of policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.

Disclosure and Sale of Personal Data

In the preceding twelve (12) months, Privee has not disclosed personal information for a business purpose.  

Privee has not sold and will never sell personal information.

Storage and Transfer of Personal Data

The personal data we collect may be stored and processed in your region, in the United States or in any other country where we, our affiliates, or contractors maintain facilities. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.

We also collaborate with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within Privee or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.

If you would like to know more about our data transfer practices, please contact support@priveelabs.com.

Retention of Personal Data

Data that you create within Privee’s Services, such as posts and comments in the App, will be retained for your use of our Services until you delete them from your account or delete your account.

We retain other information you provide to us, such as your log-in credentials, and analytics data we automatically collect only as long as necessary to fulfill the purpose(s) for which it was collected, comply with applicable laws, comply with audits, and enforce our Terms of Service.

What are your rights regrading your personal data?

We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.

Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data (e.g. a phone number or email) is required to provide you with the products or services you requested, or that it is required by the applicable law.

Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email or telephone about our products, services and events that may be of interest to you, including newsletters.

E-mail communications you receive from us will generally provide an unsubscribe link allowing you to opt-out of receiving future email or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. If you have an account with Privee, you can also change your contact preferences through our App. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.

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How do you opt-out of personal information sharing with our Business Partners?

We may use third party analytics vendors to evaluate and provide us with information about the use of our Services and viewing of our content.  This information allows us to create content and features of greater interest to you and improve our services. 

You may opt-out of Google analytics by visiting http://tools.google.com/dlpage/gaoptout. 

However, you cannot opt-out of our contextual analytics; which is based on your usage of only our Services. We will also continue to monitor your usage to provide us with analytics on how well our Services, features, and activities are functioning and used. We will also share this information in an aggregated or anonymized form (meaning that no one individual person can be identified) within Privee.

You can also opt out of our marketing emails at any time by contacting us at support@priveelabs.com.

How do you correct and update your personal data?

We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please update it in the App. 

You can change or correct your personal data at any time in the App.

What is our privacy policy if you are an underage child?

We understand the importance of protecting the privacy of all individuals, especially the very young. Our Services are intended for audiences over the age of 13. Our Services are not directed to children, and you may not use our Services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

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What happens when you link to a third-party site?

If you click on a link and go to another site, you will be subject to that website’s privacy policy. We encourage you to read the posted privacy policy statement at any website before submitting any personal data at all.

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What happens when we update our privacy policy?

We may on occasion update our Privacy Policy. Your acceptance of any minor changes to this Privacy Policy is indicated by your continued use of our Services. If we make any material changes to our Privacy Policy, we will post a notice about the change at a prominent location on our Site and In-App. We encourage you to periodically review our Site / App and this Privacy Policy for any changes.

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What happens if we sell our business?

While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another company or individual, or that it might buy certain assets of another company or individual. If all or part of the company is sold, merged or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction. However, we will take steps to ensure that your personal information is used in a manner consistent with the provisions of our Policy.

What if you have questions?

If you have questions or concerns regarding this statement, you should first contact us via email at support@priveelabs.com.

Privacy Notice for California Residents

If you're a California resident, you can learn more about your consumer privacy rights by reviewing the California Privacy Notice.