Our Privacy Policy


 

Timehop Inc. ('Timehop' or 'we' or 'us') is committed to protecting your privacy.  We created this Privacy Policy ('Privacy Policy') to give you confidence as you visit the www.timehop.com website located within the timehop.com domain ('Site') and use the Timehop services (the 'Services') provided through the Timehop mobile application (the “Application”) and the Site, and to demonstrate our commitment to fair information practices and the protection of privacy.   Your use of the Site and the Services is governed by this Privacy Policy and the Terms of Use.

1. About This Privacy Policy and Our Services

This Privacy Policy is only applicable to the Services and the Site and not to any other applications or websites that you may be able to access from the Services or the Site (whether through an advertisement, service, or content link) or any application or website of Timehop's partners, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

While you may use some of the functionality of Timehop without registration, much of the content on the Site and the Services require registration by downloading the Application for iOS or Android.  If you use our Site without downloading the Application, the only information we collect will be through the use of Cookies or Web Beacons (please see Section 2).  If you choose to download the Application, we require you to submit certain Personal Information, which is information that personally identifies you (please see Section 3).  You are responsible for ensuring the accuracy of the Personal Information you submit to Timehop. Inaccurate information will affect the information you receive when using our Site and the Services and our ability to contact you as described in this Privacy Policy.

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.

A. Cookies

We use 'cookies' to customize your experience on the Site.  'Cookies' are small computer files that are transferred to your computer's hard drive that contain information such as your user ID, user preferences, the pages you've visited and the activities you've performed while using the Site and Services. We do not link the information stored in cookies to any of your Personal Information you submit while using the Services.  You may block cookies or delete cookies from your hard drive; however, by disabling cookies, you may not have access to all of the features of the Site.  Some of our business partners also use cookies to provide us with anonymous data and information regarding your use of the Site and Services. We do not have access or control over these cookies, our privacy policy does not cover the use of third party cookies.

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.

B.  Inquiries

Subject to the Privacy Policy, if you contact Timehop, we may use any of the information you submit in connection with your inquiry, or any other information we have collected from you when responding to your inquiries.  

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

From time to time the Timehop market research department, or its operations contractors acting on its behalf, may conduct online research in order to gather feedback about our Site and our sponsors through email invitations, pop-up surveys and online focus groups. When participating in a survey, we may ask you to submit Personal Information. This Personal Information is used for research purposes, and is not used for sales solicitations. When a survey is sponsored by a third party, aggregate information of the survey results is reported to the sponsor. Personal Information collected through market research will be used only by Timehop and its service providers and contractors and will not be given or sold to third parties other than such service providers or contractors without your consent or as otherwise permitted by this Privacy Policy. We will not knowingly accept survey responses from or conduct interviews with any person under the age of 18. In addition to collecting survey responses from our members, cookies may be used to authenticate respondents or to help you pick up where you left off in a survey. If you have cookies disabled you may not be able to participate in some studies. Cookies may be used to connect survey data with Timehop site usage characteristics. You will be notified when we would like to use cookies in this way and your consent will be requested for these cookies.

4. Information Collected by Third Parties Not Acting on Behalf of Timehop

Certain content and Services offered to you through our Site and Application are served on websites hosted and operated by a company other than Timehop ("Third Party Contractor Websites"). Timehop does not disclose information collected from you to these Third Party Contractor Websites, other than unique device identifiers and information disclosed with your explicit consent, but you should be aware that any information you disclose once you access these other websites is not subject to this Privacy Policy. Timehop does not endorse and is not responsible for the privacy practices of these Third Party Contractor Websites. You should review the privacy policy posted on any other website to understand how that Third Party Contractor Website collects and uses your personally identifiable information.

5. Third Party Websites

The Site may contain links to third party websites to which Timehop has no affiliation.  Timehop does not share your personal information with those websites and is not responsible for their privacy practices. Some websites may have the look and feel of our Site. Please be aware that this Privacy Policy only covers our Site. Should you decide to visit third party websites, we suggest that you read their privacy policies.

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

We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Personal Information and Traffic Data with other companies and people who assist us by performing core services (such as website hosting, data storage and security, marketing assistance and customer service) related to our operation of the Site and/or by making certain Services available to our users. Those business partners and agents shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to and to provide you with Site related services. Timehop may share aggregated demographic information with business partners, and anonymized information with analytics and advertising partners. When you post information on the Site or through the Services, your name and certain profile information may be visible to other users. 

 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: 

  • Performance of a contract – When you download our Application, we need to collect and use some of your Personal Information to perform our agreement with you to deliver the Services in accordance with our Terms of Service and this Privacy Policy. 
  • Consent – We may also collect, use or disclose some additional Personal Information as described in this Privacy Policy subject to your consent. 
  • Legitimate interests – Finally, we may use your Personal Information for our legitimate interests to provide and improve our Services. To create your personal daily time capsule and deliver it to you each day through our Application, we need to access and use your Personal Information. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

8.  Opt-in / Opt-out

When you register for our Services, if your location indicates you are an EU user, we will request that you to opt-in, i.e. click a button, to receive our Services. We will further request that you check a box if you agree that we may use your e-mail address to send marketing messages to you. If you do not check that box, you will not receive our marketing messages. If you checked the box to agree but you no longer wish to receive emails from us, you may opt-out of receiving them by following the instructions included in each email, or by emailing us at privacy@timehop.com. You may also contact us as described in Section 13 below. If you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Site and Services.

If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data. We will provide you with an opt-out or opt-in choice before we share your data with third parties other than our business partners and agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. Timehop provides you with options to ‘opt-in’ or ‘opt-out’ of receiving additional information from us or having us provide your Personal Information to our partners.

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

You are able to access, add to, update and request deletion of information we have collected from and about you. When you update information, however, we often maintain a copy of the unrevised information in our records. 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

Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of New York state law. 

11.  European Union Visitors; Rights under GDPR

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 privacy@timehop.com. 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.

Timehop commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints should first contact Timehop at: 

privacy@timehop.com

or

Timehop Inc.
401 Broadway, Suite 1100
New York, NY 10013
Phone 347-704-0641

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

12. Changes to This Privacy Policy

We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we do, then we will notify you here, as well as by posting a notice on our Site or by e-mailing you. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

13. Contact Information

If you have any questions or comments about this Privacy Policy, please contact us at privacy@timehop.com. You may also contact us at:

Timehop Inc.
401 Broadway, Suite 1100
New York, NY 10013
Phone 347-704-0641

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.


Effective July 12, 2018