2. Information We Automatically Collect About You
Even if you do not download the Application, we collect certain information about your use of our Site and Services. Timehop collects information about devices accessing the Services, including type of device, which operating system is used, device settings, application IDs, and unique device identifiers.
B. Web Beacons
We or our third party tracking utility company also use 'web beacons' to collect anonymous information about your use of our Site and Services and the websites of selected sponsors and advertisers, and your use of emails, special promotions or newsletters we send to you. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user's browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services and selected sponsors' and advertisers' sites and opening our emails, and for what purposes. Our web beacons are not used to track your activity outside of our Site or Services or those of our sponsors'. We do not link information from web beacons to Personal Information you have submitted without your permission.
C. Traffic Data
We automatically track and collect the following categories of information when you visit our Site or use our Services: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring source which may have sent you to the Site; and (6) other information associated with the interaction of your browser and the Site (collectively 'Traffic Data'). We do not link Traffic Data to other information we have collected from you Information without your permission.
3. Personal Information We Collect From Users Who Download Our Application
A. Collection and Use of Personal Information
In order for you to access certain areas of the Site and for you to use the Service, we require you to provide us with certain Personal Information. Personal Information may include, without limitation, your first and last name, email address, age, date of birth, gender, phone number, time zone and location data, and usernames for third party social networking and other services where you have contributed content to which you grant Timehop access. These services may include but are not limited to Twitter, Facebook, Swarm, Instagram, YouTube, Tumblr, Dropbox, Google, Photo Gallery, Camera Roll, and SMS/text messaging services. We may require you to provide us with certain content you have contributed to such third party services, which may be publicly available from social media sites, use information regarding your use of our Service, and browser information. We may require you to create a password to use the Application.
We use the Personal Information that you provide to respond to your questions, provide you the specific services you select and send you emails about Site and Services maintenance and updates. We may use your contact data to send you information about Timehop or our products or Services, to contact you when necessary and in conjunction with your use of certain Services. We may use your Traffic Data to customize and tailor your experience on the Site and Services, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. You may choose not to provide us with any Personal Information. In such case, you can still access the Site; however, you will not be able to access and use those portions of the Site that require your Personal Information or be able to use our Services.
C. Email to You
We may use your contact data to send you information to contact you when necessary, including registration verification emails, and in conjunction with your use of the Services, including e-mails containing content from third party sites and services which you have permitted Timehop to access.
D. Market Research
4. Information Collected by Third Parties Not Acting on Behalf of Timehop
5. Third Party Websites
If you register for the Service and grant Timehop access to accounts you may have with third party service providers, Personal Information that you post to your accounts with those third party service providers may be viewable on or through the Site and Services, subject to the privacy settings you have set in your third party accounts.
6. Disclosure of Your Information
Timehop’s accountability for personal data that it receives in the United States under the EU-US Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Timehop remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Timehop proves that it is not responsible for the event giving rise to the damage.
Last, we may transfer information about you to another company in connection with a merger, sale of assets or the business or acquisition by or of Timehop. If Timehop, or substantially all of its assets were acquired, or in the unlikely event that Timehop 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 Timehop may continue to use your Personal Information as set forth in this policy.
Timehop does not share, sell, rent or trade your Personal Information with any third parties for their promotional purposes.
We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights, the rights of any third party and/or comply with a judicial proceeding, court order, or legal process served on our Site or Services, or in urgent circumstances to protect the personal safety of users of our Services or members of the public. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
7. Grounds for Using Your Personal Information
We rely on the following legal grounds to process your Personal Information, namely:
8. Opt-in / Opt-out
A. Marketing Opt-in
We will provide you with an opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our business partners or agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
C. INTEREST-BASED ADVERTISING IN THE APPLICATION
To opt out of interest-based advertising in the Application, follow these instructions:
iPhone/iOS: To “Limit Ad Tracking” on the iOS, please visit
https://itunes.apple.com/us/app/timehop-memories-then-now/id569077959?mt=8 or see the instructions below:
Go to “Settings” > “Privacy” > “Advertising.”
Turn on “Limit Ad Tracking.”
Android: To opt out of interest-based ads in the Android OS, please visit privacy
https://play.google.com/store/apps/details?id=com.timehop or see the instructions below:
Open Google settings on your device (may be an app called Google Settings or an entry in your phone’s Settings menu, depending on your device)
Switch on “Opt out of interest-based ads” or “Opt out of Ads Personalization.”
D. CROSS-DEVICE TARGETING
Timehop and our ad partners may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers and on each of your mobile devices. You must opt out separately on each of your browsers and each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.
E. USE OF LOCATION
To disable the collection of approximate location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.
Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you can uninstall the relevant program(s).
iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.
9. Information Security
Timehop maintains appropriate technical, security and organizational measures to protect your Personal Information against unauthorized or unlawful processing and use, and against theft or disclosure. Your Timehop account information is protected by a password for your privacy and security. We use industry-standard Secure Socket Layer (SSL) software to protect the security of your Personal Information during transmission, which encrypts all of the information you input. Only employees or agents who need personal information to perform a specific job are granted access to it. All of our employees are kept up to date on our privacy and security practices. While Timehop uses commercially reasonable means to secure your information, we do not guarantee that your personal information will not be improperly accessed, disclosed, or destroyed by breach of any of our safeguards.
10. Access and Retention of Information
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
You may delete your Timehop account by following the deletion process set forth on the Application. Some information may remain in our records after deletion of your account.
Timehop will retain your information in accordance with your instructions, as necessary to fulfill the purposes for which it was collected, and as required by applicable law. Certain information, such as photographs and associated metadata collected from your social media accounts is automatically deleted by Timehop every seven (7) days. Timehop may retain your Information after you have deactivated your account for the period of time needed for Timehop to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
11. Conditions Of Use
12. For EU Individuals: Privacy Shield Notice for Personal Data Transfers to the United States.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Timehop is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the Privacy Shield Principles, Timehop commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Timehop at:
401 Broadway, Suite 1100
New York, NY 10013
Timehop has further committed to refer unresolved Privacy Shield complaints to the BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the Better Business Bureau or visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the Better Business Bureau are provided at no cost to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
If you are a resident of the European Union, you have the right to:
request an accounting of all personal information that we possess that pertains to you in an electronically portable format.
request that we change any personal information that pertains to you.
request that we restrict or delete any personal information that pertains to you.
fully or partially withdraw your consent to the collection, processing, and/or transfer of your personal information. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case we processed your Personal Information for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Information for such marketing purposes.
You also have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Our representative in the EU for personal data purposes is Foley Hoag AARPI. You can contact our representative at the following address: 153 rue du Faubourg Saint Honoré, 75008 Paris, France.
14. Contact Information