Privacy Policy
Last updated: March 18, 2023
Introduction
By accessing and placing an order with Simplly, you confirm that you are in agreement with and bound by the terms and conditions contained in the Terms Of Use outlined below. These terms apply to the entire website and any email or other type of communication between you and Simplly.
Popin does not intend to create account for users who are under the age of 16 or statutory age of majority as required by the laws of the country of your domicile or those who are under 18 years old when using our live streaming services. So please do not use Popin and Popin Services if you are under such age requirement.
BY ACCESSING OR USING POPIN SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND THAT YOU UNDERSTAND YOUR RIGHTS IN RELATION TO YOUR INFORMATION AND HOW WE WILL COLLECT, USE AND PROCESS IT. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE POPIN SERVICES.
Capitalized terms, if not defined here in, shall have the meaning assigned to them in the Terms and Conditions.
HOW WE COLLECT YOUR INFORMATION
In order to provide Popin Services, and improve the user experience and security of Popin Services, we will collect, record, store, adapt, use, share or otherwise process your personal information, when you register a Popin account and use Popin Services.
We collect your personal information on the following grounds:
i. We need to process such information to deliver contractual services to you.
ii. You consent to provide us when you create an account and use Popin Services.
iii. We collect when we believe it is for our legitimate interests in order to provide you better experiences with Popin Services.
Information Needed for Contractual Services
We process the following personal information only as necessary to deliver contractual services as illustrated in the Terms of Use to you:
• Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier.
• Payment information, such as bank account number, PayPal or other payment information where required for the purpose of payment.
Information You Consent to Provide
You consent to provide some or all of the following personal information when you create an account on the App or use Popin Services, such as uploading contents on the App or contact us for technical support:
• Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career.
• User generated contents (“UGC”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Popin Services.
• Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Popin Services, but such data will only be processed offline to fulfil the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into deidentified data, further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party.
• Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts.
• Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device.
• Your opt-in choices and correspondence with us, such as information used to verify your account or to resolve your feedbacks or complaints.
• Information you provide when participating in in-app surveys and activities.
• Information you provide from such third-party social media when you create a Popin account by connecting with a third-party social media, such as Facebook, Instagram, Google, or if you link a Popin account with a third-party social media account. The third party’s collection, use and disclosure of your information will be subject to that third-party service’s privacy policy. In particular for your information from Google (http://www.google.com/policies/privacy), you can manage and revoke Popin Google integration’s access to your data via the Google security settings page at https://security.google.com/settings/security/permissions.
Information We Collect for Legitimate Interests
We may collect some or all of the following Personal Information about you when you use Popin Services for legitimate interests:
• Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed, and information regarding your interaction with other users.
• Information about you from third-party service providers, such as advertising partners and data analytics providers.
• Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services.
• Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address.
• Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests.
• Metadata, associating with the UGC you provided us, which describes other data and provides information about how, when, and by whom the piece of UGC was collected and how that UGC was formatted, such as hashtags used to label the keywords to the video and captions.
• Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Popin Services, enhance your experience using Popin Services, and provide you with targeted advertising on Popin Services and elsewhere across your different devices.
We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, or to calculate ad impressions served or clicked on.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).
HOW WE USE YOUR INFORMATION
We may share your information with certain authorized third parties to assist in the improvement and optimization of Popin Services, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes, including but not limited to:
• to our business partners so that we can improve Popin Services,
• to third-party advertising partners so that they can deliver ads they believe are relevant to you in other third party apps,
• to cloud storage providers to store the information you provide,
• to analytics and search engine providers that assist us in the optimization and improvement of the user experience on Popin Services,
• to IT service providers,
• to any member, subsidiary, parent, or affiliate of our corporate group.
Except for the above, we will not disclose or share with any third party your personal information, unless under the following circumstances:
• if we obtained your consent, either implied or express,
• if we are required to do so in order to comply with the applicable laws and regulations and government requests,
• If we believe in our good faith that this is necessary to protect the public interest,
• If it is necessary to do so to protect the safety and fundamental rights of another person,
• If it is necessary to address fraud, security, or technical issues,
• If it is necessary to ensure the enforcement of our terms and conditions and the daily operation of Popin Services.
YOUR RIGHTS
Pursuant to the applicable laws and regulations of the jurisdiction whereyou reside, you may have some or all of the following rights:
• Access and update certain personal information that you have provided with us by logging into your Popin account and using the features and functionalities available there.
• You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings.
• Rectify and delete your personal data retained on Popin Services.
HOW WE TRANSFER YOUR INFORMATION
We maintain servers around the world and your information collected by us are firstly stored and processed in servers nearest to your region, but in several cases your information may be stored and processed in any other country where we maintain data collection facilities. We have complied with relevant applicable data localization rules with respect to our data transfer practices. We take appropriate steps to ensure that the information we collected is processed in accordance with the privacy policy and the relevant applicable laws and regulations. If we provide any information about you to any legal agency, we will take appropriate measures to ensure such receiving institutes protect your information adequately in accordance with this privacy policy and the applicable laws.
HOW LONG WE KEEP YOUR INFORMATION
We use the following criteria to determine the period for which we will keep your information:
• our contractual obligations and rights in relation to the information involved,
• obligation(s) under the applicable laws and regulations to retain data for a certain period of time,
• statute of limitations under the applicable laws,
• our reasonable business purposes,
• disputes or potential disputes.
We retain your information for as long as it is necessary to provide you with Popin Services so that we can fulfil our contractual obligations and rights in relation to the information involved, or for other legitimate purpose such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs vary for different type of information, the context of our interactions with you or your use of Popin Services result indifferent retention periods for different type of information. Where we do not need your information in order to provide Popin Services to you, we retain it only for so long as we have a reasonable business purpose in keeping such data.
HOW TO MANAGE YOUR INFORMATION
The privacy settings allow you to control whether or not to share certain information and whether you wish to entertain certain functions.
You may download and save the short videos or sound tracks you have shared through Popin Services. If you need to download the short videos or soundtracks you uploaded on a massive basis (more than 100 files), you may email us for help.
You may also delete your account. To delete your account, you may use the“Delete Account” function available at Setting or email us indicating inEnglish that you would like to delete your account, after which you will receive instructions from us. You will need to follow our instructions in order to delete your account. Once your account is deleted, you will not be able to restore your account and all your historical data on Popin Services will be deleted after certain period of time (usually within 24 months), expect for certain behavioral data which will be anonymized for statistical research.
Note that certain third parties may retain copies of your information even after your Popin account has been deleted.
SECURITY OF YOUR INFORMATION
We take appropriate administrative, technical and physical security measures to safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your personal information. You should use caution whenever submitting information through Popin Services and take special care in deciding which information you provide us with.
You are responsible for maintaining the secrecy of your password and account information at all times.
CHILDREN PROTECTION
Popin Services is not directed to children, and if you are under the age of 16or statutory age of majority as required by the laws of the country of your domicile or under 18 if you use our live streaming services, you may not create Popin account or use Popin Services. We have zero tolerance to any form of child abuse or exploitation. Your data (including private messages) may be shared with legal agencies if we in our good faith believe that you have engaged in child abuse, or if we are requested to do so by relevant legal agencies.
MODIFICATIONS
We may amend any of the terms of the privacy policy by posting the terms. 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 Popin Services 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 Popin Services.
GRIEVANCE OFFICER
Popin has Grievance Officer to address your concerns regarding data safety, privacy, and the platform usage concerns. We will resolve the issues raised by you within 15 (fifteen) days from receiving them. You may contact Mr. Vijith KK, Grievance Officer at vijith@popin.to.
CONTACT INFORMATION
If you have any questions about this privacy policy or our information-handling practices, please contact us at support@popin.to.
Nowflow Technologies Pvt Ltd
#229, Axis Anthara, Akshyanagar,
Bengaluru 560068.