Clash App, Inc. (“Huddles”, “Clash”, “we”, “us” “our”) provides a looping video application to allow our users to create and share short-form video content. This Privacy Notice ("Privacy Notice") is designed to help you understand how we collect, use and share information about you, and to assist you in exercising privacy rights that may be available to you.
This Privacy Notice applies to personal information about you, as if you are one of the categories referenced below, that is processed by us in the operation of our business, including information handled on our websites, and mobile applications (collectively, the "Services").
The categories of personal information we collect depend on whether you are a user of our Services, job applicant or website visitor, and the requirements of applicable law.
II. Information You Provide to Us
In order to provide you with the Services, we may collect certain details or information about you. Within the preceding 12 months, we’ve collected the following types of information:
- Your Communications with Us. We collect information from you such as email address, phone number, or mailing address when you request information about our Services, request user or technical support, apply for a job or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys or otherwise provide the opportunity for you to complete services. If you decide to participate, you may be asked to provide certain information which may include personal information.
- Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered "public" and is not subject to privacy protections.
- Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
User of the Services.
- Account Creation. When you create a user account, we collect your username, email address, birthday, profile picture, biography, and certain information when you sign up/in using your Google ID or Apple ID.
- Product Interaction and Feedback. When you use our Services, we collect information regarding your interactions with our Services (e.g., engaging in certain content, comments you provide on the Services, flagging certain comments, interactions with other users, etc.), your preferences regarding our Services (e.g., notification preferences, content preferences, etc.), feedback regarding our Services, interactions and views with certain products within our Services (e.g., products of our Advertising Partners, participating in beta experiences, etc.), and transactions and requests you make.
- Applicant Details. When you apply for or express interest in employment with us, we collect information included in your resume or CV, references, background checks and job history in order to evaluate your candidacy and process your application for employment.
Information Collected Automatically or From Other Sources
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
- Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics products to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google's collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Other users of the Services, for example, when another user provides us with information about you or interacts with you within our Services (e.g., via comments or tags).
- If you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your user identifier and email, stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
- We may use third-party application programming interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect information about you, including personal information, for various purposes including to provide analytics services and content that is more relevant to you. For more information about our collection and use of APIs and SDKs, please contact us as set forth below.
- Advertising partners that collect information regarding your activities and your device and targeted advertisements to you may have interacted with in the Services or on third party websites within their networks.
- Social media and social networking platforms, for example when you click a link to access the Services, or apply for a job using information contained in your profile from a social networking platform (e.g., LinkedIn).
- Service providers and other similar entities collecting or processing information about you on our behalf, for example, to store information we use and process as part of our Services.
- Other sources, such as from publicly available sources.
III. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to:
Fulfill our contract with you in order to provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;Communicating with you about your account, activities on our Services and policy changes;
- Undertaking activities to verify or maintain the quality or safety of a service or device;
- Processing your financial information and other payment methods for products or Services purchased;
- Providing Services on behalf of our users, such as maintaining or servicing accounts, providing user service, and verifying user information;
- Processing applications and transactions; and
- Allowing you to register for and attend events.
Analyze and improve our Services pursuant to our legitimate interest, including:
- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services and other internal research for technological improvement;
- Ensuring internal quality control;
- Debugging to identify and repair errors that impair existing intended functionality;
- Enforcing our terms and policies and any other applicable terms.
Provide you with additional content and Services, such as:
- Furnishing you with customized advertising materials about offers, products, and Services that may be of interest, including new content or Services;
- Auditing relating to interactions, transactions and other compliance activities; and
- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
Complying with our legal obligations, such as:
- Protecting your vital interest or the rights of others, or as may be required for the public good;
- Verifying your identity and preventing fraud; and
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
Create De-Identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as demographic and location information, information about the computer or device from which you access our Services, or other analyses we create.
How We Use Automatic Collection Tracking Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may Tracking Technologies to automatically collect information through the Services. Our uses of these Tracking Technologies fall into the following general categories:
- Operationally Necessary. This includes Tracking Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance Related. We may use Tracking Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
- Functionality Related. We may use Tracking Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third-party Tracking Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
Notice Regarding Third Party Websites, Social Media Platforms and Software Development Kits. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage you to read the privacy policies of each website and application with which you interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
IV. DISCLOSING YOUR INFORMATION TO THIRD PARTIES
We have disclosed the categories of personal information we have collected (as above), in the preceding 12 months as follows:
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
- Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; user service providers; and vendors to support the provision of the Services such as email service providers.
- Advertising Partners. Through our Services, we may allow third party advertising partners to set Tracking Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions in the “Cookies and Interest-Based Advertising” subsection below in “Your Choices”.
We do not sell and have not sold personal information about you in the preceding 12 months.
We may also share information about you with third parties in the following circumstances:
- Disclosures to Protect Us or Others. We may access, preserve, and disclose any information associated with you to external parties if doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Professional Advisors. We may disclose information about you with our professional advisors, such as auditors, law firms, or accounting firms.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then information about you may be shared, sold or transferred as part of such a transaction, as permitted by law and/or contract.
- International Data Transfers. Information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards [such as the European Commission’s Standard Contractual Clauses)] to ensure that your personal information will remain protected outside of the EU and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
V. YOUR CHOICES
General. You have certain choices about personal information about you. Where you have consented to the processing of personal information about you, you may withdraw that consent at any time and prevent further processing by contacting us as described below and as permitted by law. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Email and Telephone Communications. You can use the unsubscribe link found at the bottom of emails that we sent to opt out of receiving certain future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Notice).
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
"Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of certain Tracking Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners' use of this information for interest-based advertising purposes.
VI. Your Privacy Rights
In accordance with applicable law, you may have the following rights as prescribed by applicable law and subject to any exceptions and verification requirements.
If you would like to exercise any of below rights, contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request.
Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.
California. Where applicable, if you are a California resident you may have the following rights under the California Consumer Privacy Act (CCPA) in relation to “personal information” we have collected about you as defined in the CCPA
- Know/Access. You may have the right to request that we disclose certain information to you about our collection and use of certain personal information about you, including information as described below:
- The specific pieces of personal information collected;
- The categories of personal information collected;
- The categories of sources from whom the personal information is collected;
- The purpose for collecting the personal information; and
- The categories of third parties with whom we have shared the personal information.
- Right to Delete. You have the right to request that we delete the personal information.
- Freedom from Discrimination. You have the right to be free from unlawful discrimination for exercising any of the rights above.
EEA/UK. If you are located in the EEA or the UK, you have certain rights in relation to personal information about you:
- Access. You have the right to access personal information we hold about you, how we use it, and who we share it with.
- Data Portability. You may have the right in some cases to receive or have electronic personal information about you transferred to another party.
- Request Correction. You may have the right to request correction of personal information about you, where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update personal information about you or we may refer you to the entity primarily handling personal information about you, who is able to make the correction.
- Request Deletion. You have the right to request that we delete certain personal information about you, subject to certain exceptions prescribed by law.
- Request restriction of or object to processing. You have the right to request that we restrict processing of personal information about you, including the right to opt in or opt out of the sale of personal information about you to third parties, if applicable, where such requests are permitted by law.
- Withdrawal of consent. Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time by emailing us at email@example.com
- Objection to marketing. You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
VII. DATA RETENTION
We store the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services. We retain personal information data for law enforcement purposes for 90 days after a user stops using our Services. We may also retain your personal information in order to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
VIII. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice.
Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure or uses.
By using the Services or providing personal information to us, you understand that we may communicate with you electronically, including communications regarding security, privacy, and administrative issues relating to your use of the Services.
IX. CHILDREN'S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account.
X. OTHER PROVISIONS
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you and take any other steps as required by applicable law. You understand that information about you will handled in accordance with the terms of the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
XI. CONTACT US
If you have any questions about our data privacy practices or this Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please contact us at:
2219 Main Street
Santa Monica, CA 90405