Effective: May 25, 2018
Last Updated: May 23, 2018
YouNow (“Company”, “we” or “our”) is committed to safeguarding any personal data that may be collected through our mobile application, Rize, (the “App,” and the “Service”). We want you to understand how your personal data will be used and shared. The following policy describes our personal data handling practices.
WHO WE ARE AND GETTING IN TOUCH
Rize is an app developed by YouNow, Inc., whose head office is located at 245 5th Avenue 6th Floor New York, NY 10016, USA. Any questions or inquiries relating to privacy or data protection should be directed to our Data Protection Officer at firstname.lastname@example.org. EU residents may also exercise their data subject rights such as the right of access or erasure by contacting our Data Protection Officer.
The personal data we collect through Rize may be transferred to, stored at and processed by us and our affiliated third parties outside of the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. However, YouNow respects the privacy rights of its Rize users around the world. For example, we have taken important steps for compliance with the General Data Protection Regulation 2018 (GDPR) for EU users.
As a data controller, YouNow understands our obligations under the GDPR (EU) 2016/679 and has thus taken the following steps:
- Appointed a YouNow Data Protection Officer and EU Representative who can respond to EU data subjects and Data Protection Authorities as needed;
- Introduced new product features and functionality to allow Rize users better control over their privacy;
- Reviewed our data inventory and third party relationships to gain a complete picture of data flows and take a Privacy by Design approach to our data holdings;
- Enhanced our data security controls such that regardless of the data flow, our Rize user data is protected at all times;
- Developed a procedure to respond to any requests that may be received from Rize users who are EU residents regarding their data subject rights (available May 25, 2018);
- Reviewed and revised our data retention rules to ensure personal data is not retained if it is no longer in use;
- Required our third parties who we entrust with Rize user data to commit to the continued protection of such data and comply with their GDPR responsibilities as a data processor; and
- Instituted a privacy data breach response plan to ensure any privacy incidents are handled effectively and efficiently.
PERSONAL DATA THAT WE COLLECT
Our primary purpose in collecting your personal data is to optimize and enhance your Rize experience. We collect your phone number in order to register you on Rize. We also collect user generated content such as images of your broadcasts, chats, or other contributions. Please do not share highly sensitive personal data using our App. Some information about your use of our Service is collected automatically such as when you joined or left a room and how many followers you have.
Registration: When you register to use our Services, we receive certain information about you through your phone number. This information, as indicated during the registration process may include your name, mobile phone number, phone contacts’ names and their phone numbers. This registration process is required for users who would like to use the Service.
In order to use the App and or/Services, we will need you to give us permission to user your microphone and camera. These permissions are essential for us to be able to provide the Services to you.
Rize Activity: Any user generated content is collected by Rize, such as when you enter profile data, create broadcasts, chat, gift, comment or follow another user.
Communication from You: When you contact us with questions, concerns or for purposes of customer/technical support, we collect the information contained in your message, which may include your name, contact details and any other personal data you provide.
Via Surveys: We may collect your user information through surveys we conduct from time to time with respect to our Services. Participation in and providing information through such surveys is optional.
Contacts: Your contacts (names and phone numbers) will also be collected by the App, and if these contacts are Rize users, they will appear on your contact list for you if you wish to add them as Rize friends. If you don’t want Rize to access your contacts and see if they are on Rize, simply select ‘Not Now’ when asked. Keep in mind that we receive information from other Rize users who sign up for our Service, which may include your contact phone number from their mobile PhoneBook.
Metadata: Information collected behind the scenes by YouNow’s servers about your use of Rize. This includes, but is not limited to, when you last logged in, started a session or joined a room, how long you watched broadcasts and information about your device or browser.
Automated data collection does not lead to profiling that significantly affects Rize users, but simply gives YouNow a clear picture of its Rize users and influencers. For a complete listing of Rize data fields collected and used by YouNow, contact us at email@example.com.
DO NOT PROVIDE SPECIAL CATEGORIES OF PERSONAL DATA: We ask that you not send us, and you do not disclose, through a broadcast or other interaction, “special categories of personal data” as defined in the GDPR (information related to racial or ethnic origin, political opinions, religious or physiological beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or data concerning data subject’s sex life or sexual orientation).
WHAT’S PUBLIC AND WHAT’S NOT?
Information you voluntarily transmit via our Service is publicly accessible and may be viewed and used by others without any restrictions. We do not control such uses of your personally identifiable information, and by using Rize, you assume the risk and acknowledge that the personal data provided by you may be viewed and used by third parties and by us for any number of purposes.
Your user profile and most of the content you create when using our Service, such as your broadcasts, chats and gifting activity is publicly displayed to other Rize users. Most of the data that YouNow collects about your Rize activity (“metadata”) is not publicly available.
When you stream live video content or interact with the video streams in real time, this data is available to other Rize users in real time. Some metadata, such as number of friends or views, may also be published, however, most of the metadata that Rize collects is not publicly available.
HOW WE USE YOUR PERSONAL DATA
YouNow uses personal data about Rize users responsibly in order to ensure we are meeting your expectations of our Service, responding to you when you contact us and providing a safe space for Rize users.
We may use the personal data provided to us to:
- Contact you from time to time with critical information about service updates, technical issues or other information important for our Services, or to provide you with the support you are requesting, for example, if clarification is needed when you report another YouNow user;
- Receive feedback from you and inquire about any features you would like to see in future products. We may also message you through the App to promote new products or services that you may be interested in (or contact you by e-mail with your explicit consent);
- Customize, measure and improve our Services and content;
- Analyze our user database to review preferences and trends for our own internal statistical and analytical purposes, which we may use for marketing purposes and with respect to operations and development;
- Confirm the accuracy of our data with the data held by third parties;
- Prevent activity we determine to be potentially illegal, harmful or not in the public interest; and
DISCLOSURE OF PERSONAL DATA
Although YouNow makes every effort to preserve user privacy, we may need to disclose a Rize user’s personal data, in response to a subpoena, regulatory investigation or court order, to law enforcement authorities or regulators who have demonstrated their lawful authority. We may also disclose personal data for the public interest or in good faith to prevent harm to individuals. Keep in mind we also share personal data with trusted third parties in order to effectively provide our Services to users.
In addition to responding to law enforcement or regulator requests for personal data, YouNow will disclose personal data to report suspected illegal activity. For example, media files may be shared with the National Center for Missing and Exploited Children.
We may also disclose personal data to enforce our policies or respond to claims that a broadcast or other content violates the right of others. In all cases, such information will be disclosed in accordance with applicable laws and regulations.
YouNow may also share your personal data:
With third parties performing services on our behalf that have agreed to keep such information confidential (for example, for Rize user verification or analytics).
SECURING PERSONAL DATA
YouNow has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful processing of the data we collect. We have also taken steps to avoid accidental loss or destruction of, or damage to, our Rize users’ personal data. While no system is completely secure, we believe the measures implemented by our Services reduce the likelihood of a data security breach.
In addition, we recommend that you do your part in protecting yourself from unauthorized access to your account by ensuring no one else uses your mobile device when you are logged in, by logging off from our Service when not in use and by keeping your device passcode confidential.
Here are some examples of the data security controls in place for Rize (this is not an exhaustive list):
- The use of encryption when personal data is transferred to YouNow’s servers;
- Limited access to personal data by YouNow staff on a need-to-know basis, and the use of robust authentication processes (e.g. complex passwords or two-factor authentication);
- The use of data centers with effective physical and logical data security controls, and the use of reputable third parties who have demonstrated security consciousness; and
- Secure office premises and staff that are keenly aware of their data protection responsibilities.
COOKIES AND OTHER TRACKING MECHANISMS
A cookie will be used here to mean a Web cookie, being a small text file stored on your computer hard drive, or a token or “mobile cookie” placed in the Rize app’s local storage, in order to tailor the environment based on the user’s preferences, and track the user’s behavior.
YouNow uses the following types of cookies for the purposes set out below.
Essential Cookies: These cookies are essential to provide you with our Services. For example, they allow you to log in to our Website or App and help the content of the pages you request load quickly. We only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow our Website and/or App to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to parts of our platform that you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit us.
Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Service and how our Service are being used. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help improve our Services, to gather broad demographic information and to monitor the level of activity on the Rize App. We use Google Analytics for Mobile Apps and other third party analytics services for this purpose to capture page and screen views.
Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our App and/or Website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
NOT FOR CHILDREN UNDER THIRTEEN
This Service is a general audience Service, which is neither designed nor intended to collect personal data from children who are under the age of thirteen (13). You may reside in a country where local laws fix the digital age of consent to be older than 13. You may only use Rize if you have reached this age of consent, in accordance with applicable local laws. If you do not meet the digital age of consent of your country, you must immediately cease using our Services.
ACCURACY OF INFORMATION COLLECTED
YouNow wants to keep the personal data we store about Rize users as accurate and complete as possible. We rely on the user to provide accurate information and we also have protocols in place to promote data integrity.
The information that we collect from you is the same information that you have previously stored in your device. By updating the information in your mobile device, you may be automatically updating the information in your Rize account the next time that you log in. You can also access and modify your Rize account information directly by logging into Rize and clicking the ‘Gear Icon’.
RETENTION AND STORAGE OF THE INFORMATION WE COLLECT
Personal data this is no longer required for administrative or business purposes, and that does not need to be archived by YouNow, will be overwritten or scrambled such that it no longer identifies a Rize user. Keep in mind however that third parties who store data on our behalf have their own retention rules.
We may offer links from Rize to the sites or apps of our service providers, affiliates or unrelated companies that may be of interest to you. YouNow makes no representations as to such third parties’ practices for dealing with your personal data.
YouNow is not responsible for how other organizations or social media platforms use and share your personal data. We recommend that you check the privacy policies of any apps, sites or platforms you associate with before sharing your personal data with such third parties.
Last updated: May 23rd, 2018