Welcome to “Downtones” (the “Platform”, “We” or “us”). We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.
If you have any questions about how we use your personal data, please contact at firstname.lastname@example.org
What information do we collect about you?We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and interact with the Platform without creating an account.
How will we use the information about you?We use your information to provide the Platform to you and to improve and administer it. We use your information to, among other things, show you suggestions in the feed which you might like, improve and develop the Platform and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.
Who do we share your information with?We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.
How long do we keep hold of your information?We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims.
We collect and use the following information about you:
Your Profile Information. You give us information when you register on the Platform, including your username, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile content such as audios, images, clips, etc.
User Content and Behavioural Information.We process the content you generate on the Platform, including preferences you set (such as choice of language), photographs and audios you upload and comments you make (“User Content”). We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, image and audios you download and problems encountered, the content you like and the users you follow. We also infer your preferences, including your interests, gender and age for the purpose of personalising content. We process information about your followers, the likes you receive, the amount of downloads your content receives and responses to content you upload, for the purposes of promoting your content to other users. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.
Information from Third Parties.You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:
If you choose to register to use the Platform using your social network account details (e.g., Facebook, Google), you will provide us or allow your social network to provide us with your username and public profile, including but not limited to, your name, city, your birthday, and the list of your contacts. We will likewise share certain information with your social network such as your Platform ID, access token and the referring URL.
Advertisers and Advertising Networks
Technical Information we collect about you. We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes your IP address, browsing history (i.e. the content you have viewed on the Platform), mobile carrier, time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID and your operating system. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.
Location.We use the information about your location when accessing and/or using the Platform, if you choose to opt-in. With your permission, we may collect your GPS (Global Positioning System) data and mobile device location information. If you do not wish to share your precise location with us, you can switch off location services via the settings on your mobile device.
- You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
We may use the information we collect about/from you in the following ways:
Identify you and potentially improve and/or customize the platform;
Send you administrative notices or Account notifications;
Address inquiries and respond to customer service requests, questions and comments;
Administer your Account and manage your Account profile information;
Send you newsletters and mail (including email);
Create a more personalized User experience and customize certain content you see on the Platform;
Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings;
Improve your User experience and increase the efficiency and effectiveness of the Platform service and functionality offerings;
Ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
To enable you to socialise on the Platform, for example, by allowing other users to identify you via the "Find other friends" function or through their phone contacts;
To ensure that you are old enough to use our Platform (as required by law).
Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection;
In order to comply with our legal obligations, we use your data to help us detect abuse, fraud and illegal activity on the Platform;
We share your data with the following selected third parties:
- If you choose to register to use the Platform using your social network account details (e.g., Facebook and Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.
- Where you opt to share content on social media platforms, the audio, image, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.
We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.
We use analytics providers to help us in the optimisation and improvement of the Platform. Our third party analytics providers also help us serve targeted adverts (if you have chosen to receive personalized advertising from us and/or our partners). For more information about how our analytics providers collect data from the Platform, please see our Cookies Policy.
Advertisers and Advertising Networks
We share information with advertisers and third party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.
Our Corporate Group
We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
- comply with legal obligation, process or request;
enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- Information collected by us may be stored and processed in Germany or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent. However, we will endeavor to take reasonable measures to keep up an adequate level of data protection also when sharing your Personal Information with such countries.
- In the event that we undergo re-organization, or are sold to or merged with a third party, or sell some or substantially all of our assets, any Personal Information we hold about you may be transferred to that re-organized entity or third party in compliance with applicable law.
- In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.
You can access and edit most of your profile information by signing into Downtones. You can delete the User Content that you uploaded. We also provide a number of tools in Settings that allow you to control your uploaded content. If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live, please contact us at email@example.com.
Our Platform may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Platform is used. We use third parties to gather information about how you and others use the Platform. For example, we will know how many Users access a specific page and which User Content they clicked on. We use this aggregated information to understand and optimize how the Platform is used.
- We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.
- We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
- We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.
- After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible.
We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.
In case of any questions, comments and requests regarding this policy, you can reach us through email at email@example.com
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