·
Changes to This Privacy Policy
·
How to Contact Us
·
Your California Privacy Rights
·
Biometric
Data Retention for Illinois Resident Users
· Notice
to European Users
Personal Information We Collect
Information you provide to us. Personal
information you provide to us through the Service or otherwise includes:
·
Contact
information, such as your first and last name, email and mailing
addresses, and phone number.
·
Content
you choose to upload to or post on the Service, such as text (including
comments and messages), images, audio, and video, along with the metadata
associated with the files you upload.
- Profile information, such
as your username and password that you may set to establish an online
account with us, your photograph, interests, and preferences.
·
Biometric
information, such as facial scans of photographs and other images you
upload to the Service, and data derived from this information, as well as information
about your physical movements when you use the camera in connection with the
Service.
·
Demographic
Information, such as your city, state, country of residence, postal code,
gender and birthdate.
- Resume information, such as
details about your educational history and work experience you provide when
you submit an application for employment with Octi.
- Precise geolocation
information, such as when you authorize our mobile app to access
your location.
- Feedback or correspondence, such as
information you provide when you contact us with questions, feedback, or
otherwise correspond with us online.
- Usage information, such as
information about how you use the Service and interact with us and/or
others through the Service which we may observe and/or record in real time.
- Marketing information, such as
your preferences for receiving marketing communications, and details about
how you engage with our communications.
Information
we obtain from social media platforms. If you choose to login to the Service via a third-party platform or
social media network, or otherwise connect your account on the third-party
platform or network to your account through the Service, we may collect
information from that platform or network. For example, this information may include
your Facebook username, user ID, profile picture,
cover photo, and networks to which you belong (e.g., school, workplace). You
may also have the opportunity to provide us with additional information via the
third-party platform or network, such as a list of your friends or connections
and your email address, and which of your friends also use the Octi app. Our collection and processing of the information we obtain
from social media platforms is governed by the requirements these social media
platforms impose on us in their relevant terms and conditions. You can read
more about your privacy choices in the “Third
party platforms or social media networks” portion of the “Your Choices” section.
Information about others.
If
you decide to invite a third party to use the Service, we will collect your and
the third party’s names and e-mail addresses or mobile telephone numbers in
order to send an e-mail or SMS message invitation to the third party. We rely
upon you to obtain whatever consents from the third party that may be required
by law to allow us to access and upload the third party’s names and e-mail
addresses as required above. You or the third party may contact us at info@supermediafuture.com to request
the removal of this information from our database.
Cookies and Other Information Collected by
Automated Means
We, our service providers, and
certain third parties (e.g., online advertising networks and their clients) may
automatically log information about you, your computer or mobile device, and
activity occurring on or through the Service. The information that may be
collected automatically includes your computer or mobile device operating
system type and version number, manufacturer and model, device identifier (such
as the Google Advertising ID or Apple ID for Advertising), browser type, screen
resolution, IP address, the website you visited before browsing to our website,
general location information such as city, state or geographic area; and
information about your use of and actions on the Service, such as pages or
screens you viewed, how long you spent on a page or screen, navigation paths
between pages or screens, information about your activity on a page or screen,
access times, and length of access. Our service providers and other third
parties may collect this type of information over time and across third-party
websites and mobile apps. On our webpages, this information is collected using
cookies, browser web storage (also known as locally stored objects, or “LSOs”),
web beacons, and similar technologies, and our emails may also contain web
beacons. In our mobile app, we may collect this information directly or through
our use of third-party software development kits (“SDKs”). SDKs may enable
third parties to collect information directly from our App.
How
We Use Your Personal Information
We use your
personal information for the following purposes and as otherwise described in
this Privacy Policy or at the time of collection:
Biometric and Non-Biometric
Personal Information:
To provide
the facial-recognition features of the Octi mobile app. We
use your personal information to provide the facial recognition features of the
Octi mobile app, including to establish your user profile and account, to
identify and locate the profiles of other Octi mobile app account holders, and to
allow you to create and edit photos, videos and other content through the app.
To
comply with law. We use your personal
information as we believe necessary or appropriate to comply with applicable
laws, lawful requests, and legal process, such as to respond to subpoenas or
requests from government authorities.
For compliance, fraud prevention, and safety.
We may use your personal information and
disclose it to law enforcement, government authorities, and private parties as
we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety
or property (including by making and defending legal claims); (b) enforce
the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent,
harmful, unauthorized, unethical or illegal activity.
Additional
Uses of Non-Biometric Personal Information:
To provide,
operate and improve the Service. We
use your personal information to provide, operate and improve the Service,
including to establish and maintain your account on the Service, facilitate your to login to the Service via third-party
identity and access management providers, such as Snapchat and Facebook, enable
security features of the Service, such as by sending you security codes via
email or SMS, and remembering devices from which you have previously logged in,
facilitate social features of the Service, such as by identifying and
suggesting connections with other users of the Service and providing chat or
messaging functionality, communicate with you about the Service, including by
sending you push notifications, announcements, updates, security alerts, and
support and administrative messages, understand your needs and interests, and
personalize your experience with the Service and our communications, provide
support and maintenance for the Service, provide information about our products and services, and respond to your requests,
questions and feedback.
For
research and development. We analyze use of the Service to analyze and improve the Service and to
develop new products and services, including by studying user demographics and
use of the Service.
To send you marketing and
promotional communications. We may send you Octi-related marketing communications as permitted by
law. You will have the ability to opt-out of our marketing and promotional
communications as described in the Opt
out of marketing section below.
To display
advertisements. We work with advertising partners to
display advertisements on the Service or elsewhere online. These advertisements
are delivered by our advertising partners and may be targeted based on your use
of the Service or your activity elsewhere online. To learn more about your
choices in connection with advertisements, please see the section below titled
“Targeted online advertising.”
To manage our recruiting
and process employment applications. We use personal information, such as information submitted to us in a
job application, to facilitate our recruitment activities and process
employment applications, such as by evaluating a job candidate for an
employment activity, and monitoring recruitment statistics.
With your
consent. In some cases we
may specifically ask for your consent to collect, use or share your personal
information, such as when required by law.
To
create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data
from your personal information and other individuals whose personal information
we collect. We make personal information into anonymous, aggregated or de-identified data by removing information
that makes the data personally identifiable to you. We may use this anonymous,
aggregated or de-identified data and share it
with third parties for our lawful business purposes, including to analyze and
improve the Service and promote our business.
How
We Share Your Personal Information
We do not
share your personal information with third parties without your consent, except
in the following circumstances or as described in this Privacy Policy:
Biometric and
Non-Biometric Personal Information:
Service
providers. We may share your personal information with service providers
that perform services on our behalf or help us operate the app (such as
customer support, hosting, analytics, email delivery, marketing, and database
management services). We do not authorize these third parties to use your
personal information other than to provide the services.
To comply with law. We may share
your personal information as we believe necessary or appropriate to comply with
applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities
For
compliance, fraud prevention and safety. We
may share your personal information for the compliance, fraud prevention and
safety purposes described above
.
Business
transfers. We may sell, transfer or otherwise share some or all of
our business or assets, including your personal information, in connection with
a business transaction (or potential business transaction) such as a corporate
divestiture, merger, consolidation, acquisition, reorganization or sale of
assets, or in the event of bankruptcy or dissolution.
Additional
Sharing of Non-Biometric Personal Information:
Partners.
We may sometimes share your personal information with partners or enable
partners to collect information directly via our Service. For example, if you
choose to integrate your Snapchat account with your Octi account, Snapchat may
collect information about your use of the Service. You may view Snapchat’s privacy
policy here
.
Third-party
platforms and social media networks. If
you have enabled features or functionality that connect the Service to a
third-party platform or social media network (such as by logging in to the Service
using your account with the third-party, providing your API key or similar
access token for the Service to a third-party, or otherwise linking your
account with the Service to a third-party’s services), we may disclose the
personal information that you authorized us to share. We do not control the
third party’s use of your personal information.
Other users
of the Service and the public. We may provide
functionality that enables you to disclose personal information to other users
of the Service or the public. For instance, you may be able to maintain a user
profile with information about yourself that you can make available to other
users or the public, and you may be able to communicate with other users of the
Service via a chat or other messaging functionality. You may also be able to upload
content to the Service (such as comments, reviews, photos, and videos) which
will be displayed alongside your username and a link to your user profile, and
viewable by other users of the Service and/or the public. We do not control how
other users or third parties use any personal information that you make
available to other users or the public.
Professional
advisors. We may disclose your personal information to
professional advisors, such as lawyers, bankers, auditors and insurers, where
necessary in the course of the professional services that they render to us.
Your Choices
In this
section, we describe the rights and choices available to all users. Users who
are located within the European Union can find additional information about
their rights below.
Account information. You
may review and update certain personal information in your account profile by
logging into your account. You may also contact us at support@supermediafuture.com to request that we close your account, in which case we will close
your account as soon as practicable, but we may retain your information as we
deem necessary for the purposes described in this Privacy Policy.
Marketing communications. You may opt out of marketing-related emails by following the opt-out or
unsubscribe instructions at the bottom of the email. You may continue to
receive service-related and other non-marketing emails.
Cookies and browser web storage. We may allow service providers
and other third parties to use cookies and similar technologies to track your
browsing activity over time and across the Service and third party websites.
Most browsers let you remove or reject cookies. To do this, follow the
instructions in your browser settings. Many browsers accept cookies by default
until you change your settings. Please note that if you set your browser to
disable cookies, the Sites may not work properly. Similarly, your browser
settings may allow you to clear your browser web storage.
Privacy
settings and location data. We make available certain
privacy settings on the Service, including options to grant and revoke
permission to access to your mobile device’s contacts, camera, camera roll, and/or
microphone. You can adjust these permissions in the mobile app “Account
Settings,” or through the device-level settings on your mobile device. We may
also send push notifications to your mobile device. If you no longer wish to
receive push notifications, you can adjust your permissions in “Account
Settings” and/or turn push notifications off at the device level. Users of our
mobile app also have the choice whether to allow us to access your precise
location data. You may revoke our ability to access your location data through
the mobile app “Account Settings” and/or the device-level settings on your
mobile device.
Do Not Track.Some Internet browsers may be configured to send “Do Not Track” signals
to the online services that you visit. We currently do not respond to “Do Not
Track” or similar signals. To find out more about “Do Not Track,” please visit
http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or
where we need your personal information in order to provide the Service to you,
if you do not provide this information when requested (or you later ask to
delete it), we may not be able to provide you with our services. We will tell
you what information you must provide to receive the Service by designating it
as required at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or
social media network, you may have the ability to limit the information that we
may obtain from the third-party at the time you login to the Service using the
third-party’s authentication service or otherwise connect your account.
Subsequently, you may be able to control your settings through the
third-party’s platform or service. For example, you may access and change your
settings through the Facebook settings
page for Apps and Websites. If you withdraw our ability to
access certain information from a third-party platform or social media network,
that choice will not apply to information that we have already received from
that third-party.
Other Websites,
Mobile Applications and Services
The Service may contain links to other websites,
mobile applications, and other online services operated by third parties.
These links are not an endorsement of, or representation that we are affiliated
with, any third party. In addition, our
content may be included on websites or in mobile applications or online
services that are not associated with us. We do not control third party websites, mobile applications or online services,
and we are not responsible for their actions. Other websites, mobile
applications and online services follow different rules regarding the
collection, use and sharing of your personal information. We encourage you to
read the privacy policies of the other websites, mobile applications and online
services you use.
Security Practices
We employ a number of organizational, technical
and physical safeguards designed to protect the personal information we
collect. However, security risk is inherent in all internet and information
technologies and we cannot guarantee the security of your personal information.
International
Data Transfers
We are headquartered in the United States and
have service providers in other countries, and your personal information may be
transferred to the United States or other locations outside of your state,
province, or country where privacy laws may not be as protective as those in
your state, province, or country.
Children
The app is not directed at children under the age of 13,
and our Terms of Use do not allow children under 13 years of age to use the
app. If we learn that we have collected personal information of a child under
the age of 13, we will delete it. We encourage parents with concerns to contact us.
Changes to This Privacy Policy
We reserve the right to modify this Privacy
Policy at any time. If we make material changes to this
Privacy Policy, we will notify you by updating the date of this Privacy Policy and
posting it on the Service. We may, and if required by law will, also provide notification of changes
in another way that we believe is reasonably likely to reach you, such as via
e-mail (if you have an account where we have your
contact information) or another manner through the Service.
Any modifications to this Privacy Policy will be
effective upon our posting the new terms and/or upon implementation of the new
changes on the Service (or as otherwise indicated at the time of posting). In
all cases, your continued use of the Service after the posting of any modified
Privacy Policy indicates your acceptance of the terms of the modified Privacy
Policy.
How to Contact Us
Please direct any questions or comments about this Policy or privacy
practices to octiaccountinquiries@octi.tv. You may also write to us via postal mail at:
SuperMediaFuture Inc DBA
"Octi"
Attn:
Privacy
8560 W Sunset Blvd
10th Floor
Los Angeles, CA
90069
Biometric
Data Retention for Illinois Resident Users
If you are an Illinois resident, in accordance
with Illinois state law Octi will retain your biometric data only until the
occurrence of the first of the following, after which we will permanently
destroy the biometric data:
·
The
initial purpose for collecting or obtaining such biometric data – as set out in
this Privacy Policy – has been satisfied; or
·
Three
years following your last interaction with Octi, where your last interaction is
the later of the date on which you closed your Octi mobile app account, or the
last date you communicated with us about the Octi mobile app.
Notice to European Users
The information provided in this “Notice to European Users”
section applies only to individuals residing in the Europe Union.
Personal information. References
to “personal information” in this Privacy Policy are equivalent to “personal
data” governed by European data protection legislation.
Controller. Supermediafuture Corp. is the controller of your personal
information covered by this Privacy Policy for purposes of European data
protection legislation.
Legal bases for
processing. We use your personal information only as
permitted by law. Our legal bases for processing the personal information described in
this Privacy Policy are described in the table below.
Processing purpose (click
link for details)
Details regarding each processing purpose
listed below are provided in the section above titled “How we use your personal
information”.
|
Legal basis
|
· To
provide the facial recognition features of the Octi mobile app
|
Processing is based on your consent. Where we
rely on your consent you have the right to withdraw it any time in the manner
indicated when you consent or in the Service.
|
· To
provide, operate and improve the Service
|
Processing is necessary to perform the contract
governing our provision of the Service or to take steps that you request
prior to signing up for the Service. If we have not entered into a contract
with you, we process your personal information based on our legitimate
interest in providing the Service you access and request.
|
· For
research and development
· To
send you marketing communications
· To
display advertisements
· For compliance,
fraud prevention and safety
· To create anonymous,
aggregated or de-identified data
|
These activities constitute our legitimate
interests. We do not use your personal information for these activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law).
|
To comply
with law
|
Processing is necessary to comply with our
legal obligations.
|
With your consent
|
Processing is based on your consent. Where we
rely on your consent you have the right to withdraw it any time in the manner
indicated when you consent or in the Service.
|
Sensitive personal information. If you provide us with
any sensitive personal information to us when you use the Service, you must
consent to our processing and use of such sensitive personal information in
accordance with this Privacy Policy. If you do not consent to our processing
and use of such sensitive personal information, you must not submit such
sensitive personal information through our Service.
Retention
We retain personal information for as long as necessary to fulfill the
purposes for which we collected it, including for the purposes of satisfying
any legal, accounting, or reporting requirements, to establish or defend legal
claims, or for fraud prevention purposes.
To determine the appropriate
retention period for personal information, we consider the amount, nature, and
sensitivity of the personal information, the potential risk of harm from
unauthorized use or disclosure of your personal information, the purposes for
which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal requirements.
When we no longer require the personal
information we have collected about you, we will either delete or anonymize it
or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible. If we anonymize your personal information (so
that it can no longer be associated with you), we may use this information
indefinitely without further notice to you.
Your
rights
European data protection
laws give you certain rights regarding your personal information. If you are
located within the European Union, you may ask us to take the following actions
in relation to your personal information that we hold:
- Access. Provide
you with information about our processing of your personal information and
give you access to your personal information.
- Correct. Update
or correct inaccuracies in your personal information.
- Delete. Delete
your personal information.
- Transfer. Transfer
a machine-readable copy of your personal information to you or a third
party of your choice.
- Restrict.
Restrict the processing of your personal information.
- Object. Object
to our reliance on our legitimate interests as the basis of our processing
of your personal information that impacts your rights.
You
may submit these requests by email to octiaccountinquiries@octi.tv
or to our
postal address provided above. If you
would like to submit a complaint about our use of your personal information or
our response to your requests regarding your personal information, you may contact us or submit a complaint to
the data protection regulator in your jurisdiction. You can find your data
protection regulator here
.