ZOONI PRIVACY POLICY
Last Updated: 5/19/22
BlackBoxGo, LLC d/b/a Zooni (“Zooni,” “us,” “we,” or “our”) provides the Zooni social networking platform for users to engage with others using video. This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
2……… PERSONAL INFORMATION WE COLLECT
3……… HOW WE USE YOUR INFORMATION
4……… HOW WE DISCLOSE YOUR INFORMATION
5……… YOUR PRIVACY CHOICES AND RIGHTS
6……… SECURITY OF YOUR INFORMATION
7……… INTERNATIONAL DATA TRANSFERS
8……… RETENTION OF PERSONAL INFORMATION
9……… SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10……. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
1. SCOPE
This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively referred to as the “Services.”
2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
- Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
- Account Creation. We may collect information when you create an account, such as name, email address, phone number, birthdate, username, and optional profile picture, bio, and gender information.
- Parental consent: To allow underage users to access the Services, we require parents to provide their consent, which we verify by third-party processor, SuperAwesome.
- Interactive Features. Our Services allow you to record video simultaneously from the front and rear-facing camera on your mobile device, and share these videos via the Services. In addition, we and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities and “likes,” and searches). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Videos & Audio. The Services allow users to use special functions that are designed for editing and processing videos. We may collect information about the videos and audio that are a part of your User Content, such as identifying the existence and location within an image of face and body features and attributes and the nature of the audio in your User Content. We may collect this information to enable special functionality such as special video effects, for content moderation, for content and ad recommendations, and for other non-personally-identifying operations. We may collect biometric identifiers and biometric information as defined under US laws, such as faceprints and voiceprints, from your User Content. Where required by law, we will seek any required permissions from you prior to any such collection. TrueDepth API – We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies, you may visit https://support.apple.com/en-us/HT208108. Our technology uses this information to allow for the creation of various AR effects & filters. None of the information collected by the TrueDepth API ever leaves the user’s device nor is it persistently stored on the device.
- Mobile information. With your consent, we may collect your phone number to send you SMS updates, or your phone’s push token to send push notifications.
- Payment Information. We may collect personal information and details associated with your purchases, including payment information, such as credit card, public blockchain data, or other financial information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
- Crypto Wallet Information. We may offer the ability to make purchases of non-fungible tokens (“NFTs”), which can be used to receive certain functionality or benefits on our platform. To enable this feature, we may collect your crypto wallet address, the NFTs you bid on or purchase, and the amount paid for each NFT. We may also collect other information to facilitate the transaction, verify your identity, and comply with our regulatory obligations (sometimes referred to as “Know Your Customer” checks). Such information may include, without limitation: date of birth, your passport or national ID card, a bank card statement, or other information linking you to an address.
- Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Information Collected Automatically
We may collect personal information automatically when you use our Services:
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Crash Reports. If you send them, we may also receive crash reports with more detailed diagnostic information about your device and the activities that led to the crash.
- Location Information. We may collect precise location information, such as through GPS, WiFi or cellular triangulation or otherwise use our Services. You will receive prior notice and will be asked to consent before your geolocation information is collected. If you do not wish to share your geolocation data through your device, please change the privacy settings in your device for the Services.
- Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below). For example, we may track your in-app activity, including video recordings and other interactions with the Services;
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed; and
- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
- Google Analytics. We use analytics services provided by Google Inc. This allows us to process usage data to better understand how our website and web-related Services are used. This enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data, such as cookie and other device identifiers. The data collected by Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g. for profiling or linking it to other data. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
- Social Media Platforms. Our Services may contain social media buttons, such as Facebook, Instagram, TikTok, Snapchat, and Twitter, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
- Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide information about your friends through our referral service; third parties may also use these services to upload information about you. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
3. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
- Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
- Administrative Purposes
We use your information for in our legitimate interest, or to comply with our legal obligations, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading, or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Enforcing our agreements and policies; and
- Other uses as required to comply with our legal obligations.
- Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
- Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
- Automated Decision Making. We may engage in automated decision making, including profiling, such as to suggest videos for you to watch or other users to follow. Zooni’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us”
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create. If we create or receive personal data that has been de-identified or aggregated, we will not attempt to reidentify it, except to comply with applicable law.
4. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as downloads, time spent on the Services, number of views and likes, comments, geographics and demographics, and other performance and engagement analytics, in order for them to provide services to you or support and supplement the Services we provide.
- Other Users/Website Visitors. As described above in “Personal Information We Collect,” our Services allow you to share your profile and/or User Content with other Users/publicly, including to those who do not use our Services.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us”
- Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
- Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us, or by otherwise contacting us.
- Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to our processing of your personal information; and
- Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
6. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected, and take steps to require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our 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 our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
7. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Zooni has collected about them, and whether Zooni disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
| Category of Personal Information Collected by Zooni | Category of Third Parties Information is Disclosed to for a Business Purpose |
|---|---|
| Identifiers.
A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
|
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, physical characteristics or description, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or other financial information. |
|
| Protected classification characteristics under California or federal law
Age (40 years or older), race, color, national origin, citizenship, marital status, or sex. |
|
| Biometric information
Biological characteristics that can be used to establish individual identity, or imagery of the iris, retina, fingerprint, face, and voice recordings, from which an identifier template such as a faceprint, a minutiae template, or a voiceprint, can be extracted and contain identifying information. |
|
| Internet or other electronic network activity
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. |
|
| Geolocation data
Physical location or movements. |
|
| Sensory data
Audio, electronic, visual, or similar information. |
|
| Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
|
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Zooni does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the Light” 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.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.
1. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at hello@zooni.app with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
2. CHILDREN’S INFORMATION
Protecting children’s privacy online is very important to us. Our Services are not intended for any users under 13 years old, we require the verifiable consent of parents before allowing the user to provide any personal information on our Services.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, or wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, and/or revert them to the underage experience, if applicable.
3. OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each 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. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
If you are based in Australia and you are not satisfied with how Zooni has handled your data, you may wish to contact the Office of the Australian Information Commissioner.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
4. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Zooni
22 Woodhaven Drive
Barrington, NH 03825