This policy has been last updated on July, 2021
What about Children’s Privacy?
The Services are structured to attract adults to use the system to invite guests to an event or join an event they have been invited to in order to communicate in a private online setting. The Service is not intended for independent use by children under the age of 13 years and it is not intended to collect, use, or disclose Personal Information from children under 13 years. Accordingly, we do not intend to collect Personal Information from anyone under 13 years. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information or immediately seek the parent’s consent for that collection. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect Personal Information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law.
This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding personal information of children under 13 years. For more information about COPPA and general tips about protecting children’s online privacy, please visit https://www.consumer.ftc.gov/features/feature-0038-onguardonline.
Unsolicited Information Shared by Child Users:
If an Adult Member/Parent allows their child access to their Licensor account and the child engages in some of our online activities, including sending messages, using Instant Messaging (IM), sharing photos and videos, posting on the MP event newsfeeds – they might share information that is considered Personal Information. Personal Information that we may collect appears below under the heading “What Personal Information does Licensor collect?” How we may use Personal Information and our disclosure practices appears under the heading “How do we use the information we receive?” All content posted on a private event page can only be viewed by a member of the event. It is never publicly accessible. As stated above, if we learn that we have collected Personal Information from a child under 13 years, we will delete that information or immediately seek verifiable parental consent by email for the collection. If you believe your child is participating in an activity that collects Personal Information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at email@example.com We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Although there is no foolproof system for protection of Personal Information, Licensor’s model only allows users to share with real life friends (members of the event) and as previously stated, all content posted on a private event page can only be viewed by a member of the event. It is never publicly accessible. Should Licensor ever plan to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
Email Consent: In the event Licensor wishes to collect Personal Information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
High-Level Consent: In the event Licensor collects Personal Information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
Parental Choices and Controls:
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. Parents can contact us to request access to, change, or delete their child’s personal information by sending an email to us at firstname.lastname@example.org. A valid request to delete personal information will be accommodated within a reasonable time.
What Personal Information does Licensor collect?
A. The data we collect
Licensor collects personal data:
provided by users to Licensor, such as during account creation
created during use of our services, such as location, app usage, and device data
from other sources, such as other users or account owners, business partners, vendors.
B. How we use personal data
Licensor uses personal data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:
to enhance the safety and security of our users and services
for customer support
for research and development
to enable communications between users
to send marketing and non-marketing communications to users
in connection with legal proceedings
Licensor does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
Through your use of the Services, you may provide us with content, such as branding and logos, for use along with your use of the Services. This can also include information in or about the content you provide, such as the location of a photo or the date a file was created. We will use and store this content only pursuant and related to your use of the Services.
Personal information collected automatically:
We receive and store certain types of information whenever you interact with our Services. Licensor automatically receives and records information on our server logs from your browser including your IP address, cookie information, and the page you requested.
Generally, our Services automatically collect usage information, such as the numbers and frequency of visitors to our site and its components. Licensor may use this data in aggregate form, that is, as a statistical measure. This type of aggregate data enables us to figure out how often individuals use parts of the Services so that we can improve the Services and make them as appealing to as many users as possible. As part of this use of information, we may provide aggregate information to our partners about how our customers, collectively, use the Site. We share this type of statistical data so that our partners also understand how often people use their services and our Services, so that they, too, may provide you with an optimal online experience.
We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your visits to our sites to do things like optimize product design. And we also use data about the ads you interact with to help advertisers understand the performance of their ad campaigns.
Third Party Services.
Amazon Web Services
We may receive confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful and improve our service. If you do not want to receive email or other mail from us, please send an unsubscribe request through email@example.com.
Communicate with you
We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity, like an attempt to sign in to your Google Account from an unusual location. Or we may let you know about upcoming changes or improvements to our services. And if you contact Google, we’ll keep a record of your request in order to help solve any issues you might be facing.
We collect information from or about the computers, phones, or other devices where you install or access our Services. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices.
Here are some examples of the device information we collect:
Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
What about cookies?
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. Licensor cookies do not collect Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are or what your screen name or email address is.
Information to any third party ad network:
To increase the effectiveness of ad delivery, we may include a file, called a web beacon, from an ad network within the Service. The web beacon allows the ad network to provide anonymized, aggregated auditing, research and reporting for advertisers. Web beacons also enable the ad networks to serve ads to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.
Sharing of your Personal Information using the services:
Licensor will not share your Personal Information with any other users of the Services unless you so request explicitly, either in writing, or through use of applicable features of the Services.
How do we use the information we receive?
Personal Information about our users is an integral part of our business. We are dedicated to providing an engaging and customizable experience for all of our users. We may share your Personal Information only as described in this policy.
We use all the information we have to help us provide, support and improve our Services. We combine information that we receive about you (such as gender, age, geographic location, etc.) with information about your events and activities on the Site and the Services to identify trends and other statistical information. We may use this data to provide third parties with statistics that might be relevant to the marketing and sale of their goods and services. We may use data to deliver our Services, make suggestions for you by using this information to understand how you use and interact with our Services and to personalize content. When we have location information, we can tailor our Services for you like, event check in, locating an event, offers in your area. We conduct surveys for research on features in development and use this information to improve our products.
Non-Private or Non-Personal Information:
For clarity, we may share or disclose your non-private, aggregated or otherwise non-Personal Information with advertisers, service providers, and other persons with whom we conduct business. Conversely, these advertisers, service providers and other persons may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.
We do not share your Personal Information with advertisers without your consent. We may allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users) to select the appropriate audience for those advertisements. Even though we do not and will not share your information with advertisers without your consent, if you click on or otherwise interact with an advertisement there is a possibility that the advertiser may place a cookie in your browser and note that it meets the criteria they selected.
Partners, vendors, service providers:
Affiliated Businesses We Do Not Control:
In certain situations, businesses with whom Licensor becomes affiliated may sell items or provide promotions to you through the Services. In other situations, Licensor may provide services, or sell products jointly with affiliated businesses. You can easily recognize when an affiliated business is associated with your transaction, and we will share your Personal Information that is related to such transactions with that affiliated business, if you have agreed to be solicited by marketing partners.
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, Licensor’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.
Communication in response to User Content:
As part of the Services, you will receive from Licensor email and other communications. You acknowledge and agree that by availing yourself of the Services, you allow Licensor to send you email and other communication that it determines in its sole discretion relate to your use of the Services.
We may send you offers on behalf of other businesses. However, when we do so, we do not give the other business your name and address. [If you do not wish to receive these offers, please email us at firstname.lastname@example.org.
In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Moreover, if Licensor, or substantially all of its assets, were to be acquired, or in the unlikely event that Licensor goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Licensor may continue to use your Personal Information as set forth in this policy.
Protection of Marked Private and Others:
We may release Personal Information when we believe in good faith that release is necessary to comply with that law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Licensor, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent:
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information..
We may keep information that will collect for an unlimited period of time.
Please note that electronic communication, particularly email, is not necessarily secure against interception. Please do not send sensitive data (e.g., Social Security, bank account, or credit card numbers) by email or web form.
What Personal Information can I access and change?
You can access any Personal Information that you provide to Licensor, through your account settings. To the extent information appears to be missing from your account settings pages, you may contact us at email@example.com in order to inquire about the missing information. You will be able to, either through the Services or through contact with our customer support representatives, modify most of the Personal Information you provide to us.
Is Personal Information about me secure?
Your Licensor account Personal Information is protected by a password for your privacy and security. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your browser by signing off after you have finished accessing your account.
Licensor endeavors to ensure that user account information is kept private. However, Licensor cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Deleting your account:
Should you ever decide to delete your Licensor account, you may do so by contacting us at [*****]. If you terminate your account, your profile will be removed from the site and deleted from Licensor’s servers. Because of the way we maintain Licensor, such deletion may not be immediate, and residual copies of your profile information or posts may remain on backup media. Even after your account is terminated, Licensor may retain and use certain data contributed by you, indefinitely.
What choices do I have?
As stated previously, you can always opt not to disclose information to use, even though it may be needed to take advantage of certain aspects of the Services.
In certain circumstances, you are able to add or update certain information on pages as described in the “What Personal Information Can I Access” section above. When you update information, however, we may maintain a copy of the unrevised information in our records.
What happens when I invite Friends?
Questions or concerns:
If you have any questions or concerns regarding privacy using the Service, please send us a detailed message to: firstname.lastname@example.org We will make every effort to resolve your concerns.