FlexTogether Privacy Statement
3. Transparency / Notice—Types of Personal Information We Collect and How We Use It: The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect Personal Information include:
You may provide Personal Information directly to us through interacting with the Services, signing up for an account, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
SoZango collects Personal Information regarding its current, prospective, and former clients, customers, Users, visitors, and guests (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with us, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Communications with Us. We may collect Personal Information from you such as name, email address, phone number or mailing address when you choose to request information about our Services, register for an account or a promotion that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
Contacts & Phone Numbers
When you give us authorization, we will access your contacts information from your address book on your mobile device or computer (“Contacts”). We will use your Contacts in order to identify other Users that you may know and to provide you or other Users with suggestions for other Users with whom you or they may want to connect or invite to join a video chat session. We may also use your Contacts with your authorization if you choose to invite your friends to sign up for the Services.
For example, the Services may indicate a Connection that you and one or more participants in a video chat session have in common which you may want to invite to join a video chat session. The Services may also suggest to another User a potential Connection based on mutual contacts.
In addition, if you use your phone number to verify your account, we may use your phone number to suggest to you other Users to add as Connections or suggest you as a potential Connection to other Users based on the Contacts they upload.
Note, however, that we will never share your phone number or the phone numbers of third parties in your Contacts with anyone else.
Registration for Sweepstakes or Contests. Occasionally, SoZango may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. In accordance with the laws of your jurisdiction, as a participant you will have the opportunity to opt-out of any communications that are not related to awarding prizes.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information Submitted Via Services. You agree that SoZango is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. 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.
3.2 How We Use Your Information
Our primary goals in collecting Personal Information are to provide and improve our Services, to administer your use of the Services (including your account, if you are a User), and to enable you to enjoy and easily navigate our Services. We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Generally manage Individual information and Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of our Services;
Contact you to answer requests for customer support or technical support;
Allow you to register for events.
Administrative Purposes. We may use Personal Information about you for its administrative purposes, including to:
Measure interest in our Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual accounts and activities on our Services and systems, and, in our discretion, changes to any SoZango policy;
Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Marketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, push notifications or text messages from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within SoZango and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we allow you to provide information about your friends through our referral services, such as “Add a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email or message inviting your friend to use our Services. Email addresses or phone numbers that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other Third Parties for any other purpose.
Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags / Web Beacons, Analytics Information, Interest-Based Advertising, and Other Technologies
Cookies. Cookies are small data files that are placed on your device’s hard disk when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services, to better understand how you interact with our Services, to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session Cookies are deleted when you log off from the Services. Most Internet browsers automatically accept Cookies. If you do not want cookies from SoZango or other services, you can change your settings to stop accepting Cookies or to prompt you before accepting a cookie from the services you visit. However, some Services may not function properly if you disable Cookies.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon, web bug, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the User’s hard drive, pixel tags are typically embedded invisibly on web pages (or in an e-mail).
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit http://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.
Log Data. Our servers automatically record information (“Log Data”) created by your use of the Services. Log Data may include information such as your IP address, browser type, operating system, location, your mobile carrier, device and application IDs, the Users with whom you video chat, access date and time spent on features of the Services and other statistics and Cookie information. We receive Log Data when you interact with our Services, for example, when you visit our websites, sign into our Services, participate in a video chat session, or interact with our email or push notifications. SoZango uses Log Data to provide our Services and to measure, customize, and improve them. For instance, SoZango may provide you with recommendations based on your use of the Services.
Location Information. In addition to profile information, if you choose to enable your computer or mobile device to send us location information we may collect and store information about your location by converting your IP address into a rough geolocation or by accessing your computer’s or mobile device’s GPS coordinates or coarse location.
We may use and store information about your location, to provide features of our Services, such as providing location specific filters, and to improve and customize the Services with Content that has been tagged near your location. If you do not want us to collect location information, you may disable that feature on your computer or mobile device.
Our uses of such Technologies fall into the following general categories:
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 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 Site or other Services. We use Third-Party software development kits (“SDKs”), such as the Facebook SDK, as part of the functionality of our Services (e.g., to suggest friends from Facebook or other platforms for your addition to your app contact list). Third-Party SDKs may allow Third Parties including advertisers to collect your personal information to provide content that is more relevant to you. You may opt out of tracking by accessing the Third Party’s settings on your device and disabling the tracking function for that Third Party or by choosing not to enable such SDKs in the settings for our Services.
These other domains, websites and services are not controlled by us, and we do not endorse or make any representations about Third-Party websites or social media platforms. We encourage our Users to read the privacy policies of each and every website and application with which they 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 or connecting to these other websites, services or applications is at your own risk.
Our Services may contain private messaging features, links and interactive features with various social media platforms (e.g., widgets to suggest friends from Facebook or other platforms to add to your contacts). If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
4. Onward Transfer—We May Disclose Your Information
4.1 Information We Share
Information Shared with other Users. As part of our Services, you may communicate with other Users through group video chat sessions or through messages.
Video Chat. You will be able to participate in a group video chat session with your Connections and the Connections of any other User that is participating in a current session. Any Connection of a participant in a video chat session may join a chat session, with or without an invite from you and whether or not you know him or her. However, if a User that isn’t your Connection is about to join a video chat session you are in, you’ll receive a notice that such a participant is joining.
Messages. You may also choose to send messages to other Users, whether or not they are your Connection.
When you participate in a group video chat session or send a message, the content of your communications (including audio and video) will be visible and available to any User participating in that session or receiving a message. We encourage you to use your judgment in communicating and sharing information with other Users.
Any other User may view your profile information on the Services, including your name, username and a list of your top Connections (i.e., who you speak to most often) on the Services, and your name or username may be displayed to other Users as a suggested Connection. In addition, if you are participating in a video chat session, any other User participating in that video chat session may be able to send a screenshot of the video chat to other Users that identifies your name and permits those other Users to add you as a Connection.
In addition to your profile, your Connections will also be able to see the last time you were online, and your Connections (including a list of recent Connections).
We are not responsible for privacy practices of the other users who will view and use the posted information.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. We have executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with us. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify Users in connection with their investigation of the unauthorized activities.
4.2 Data Transfers
All Personal Information collected via or by SoZango may be stored anywhere in the world, including but not limited to, the United States, the European Union and other international jurisdictions, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your Personal Information in these locations.
5. Opt-Out (Right to Restrict Processing)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to our Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 Email and Telephone Communications
We maintain “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
5.3 Mobile or Other Devices
We may occasionally send you push notifications through our mobile and desktop applications with updates, messages, promotions and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile or other 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 or other device.
5.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. DNT is a way for Users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6. Rights of Access, Rectification, Erasure, and Restriction
Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on or via the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. Children’s Privacy
The Services are not directed to children under 13 years of age, and we do not knowingly collect Personal Information from children under 13 years of age. If you are under the age of 13 you must have your parent’s permission to access the Services. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 without verifiable parental consent, we will promptly take steps to delete such information and terminate the child’s account.
11. Redress / Compliance and Accountability
12. Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
12.2 California Privacy Rights
California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. We do not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, SoZango or to which SoZango discloses Personal Information for use on its behalf.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, SoZango or SoZango’s Agents.