Spocien Privacy Policy, Terms of Service
Spocien Inc. ("we," "us," "our") respect your privacy and are committed to protecting it through our compliance with this privacy policy ("Policy").
This Policy describes how we collect, use, disclose and protect the personal information of the users of our website https://spocien.com/ ("Website") and our software application Spocien ("Application"), available on the iOS App Store, Appstore, Website. The use of "you" in this Policy refers to anyone who visits our Website or who uses the Application. Our Website and the Application are collectively referred to as the "Services".
This Policy also explains your choices about how we manage your personal information.
Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information, to identify, contact, or locate a single person.
This Policy applies to personal information we collect, use, or disclose about you:
· On our Website.
· Through the Application.
· In email, text, and other electronic messages between you and the Services.
The Services may include links to third-party websites, services, social networks, or applications. Clicking on those links may allow the third party to collect or share data about you. If you follow a link to a third-party website, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your personal information. If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you indicate that you understand, accept, and consent to the practices described in this Policy.
This Policy may change from time to time (see the Changes to Our Privacy Policy heading below). Your continued use of the Services after we make changes, indicates that you accept and consent to those changes, so please check the Policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU
We may collect and use several types of information from and about you, including:
· Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, e-mail address, user name or other similar identifier, and any other identifier we may use to contact you online or offline. Please note that the Services do not collect this information in the ordinary course; we only receive it, if you choose to provide it to us.
· Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, including usage information, such as videos played, screens viewed and your use of the Application's features and functions, on your device. We also collect statistical or aggregated information related to your use of the Application (such as information related to your video library, or an IDFA advertising identifier that is assigned to your profile).
· Technical information, including your IP address, device information and Spocien version number.
· Non-personal details about your interactions with the Services, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), video search queries, page response times, download errors and crash logs, length of visits to certain aspects of the Services, page interaction information (such as scrolling, clicks, and mouse-overs) or methods used to browse away from the page.
As you can see, most of the information we collect is not personal information. This is because the information does not contain any information that can be used to identify you, and we do not have the ability to link this information to your identity. We do not require you to register an account to use the Services, nor do you need to provide us your name or email address.
If you would like to opt out of any collection, use or disclosure of your information, by the Services, please email us at [email protected], and we will do our best to accommodate your request.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
· Direct interactions with you, when you provide it to us, for example, by corresponding with us by email, or otherwise.
· Automated technologies or interactions, as you navigate through our Website or use the Application. Information collected automatically may include usage details, IP addresses, and information collected through the use of your IDFA, which is the identifier that is assigned to your device by Apple for the purposes of delivering advertising content to you.
The information we collect directly from you on or through the Services may include:
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your search queries on the Application.
· Information provided through the iOS App Store, to verify your purchase of ad-free content.
· Copies of your video libraries and playlists, so that we can back them up and make them available across your devices.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your device, browsing actions, and patterns, including details of your use of the Application, including the frequency and duration of usage, as well as how you interact with advertisements that are provided in the Application. This includes information such as the unique ID of your device.
We use Google Analytics, to help us understand how you use and interact with the Services. You may opt out of Google Analytics by visiting the Google Analytics Opt-out Page.
The information we collect automatically is statistical data and does not include personal information (again, because we have no way of linking it to your name or other identifying information), and we may use and maintain it, to deliver better and more personalized Services, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Services according to your individual interests.
· Recognize you when you return to the Services.
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Services, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Services. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with behavioural advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support the Services so that you can enjoy free content.
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using opt-out tools created by the Digital Advertising Alliance of Canada or the Network Advertising Initiative. You can also access these websites to learn more about behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see the Choices About How We Use and Disclose Your Information heading below.
Our ad network providers include Mintegral North America Inc. (“Mintegral”). Mintegral provides and serves some of the ads you may see on the Services. This is accomplished through the embedding of software development tools provided to us, by Mintegral, into the Services. These software development tools then enable the display of ads, from advertisers, which are provided to us by Mintegral.
Mintegral may collect the following information from you, when you view ads that it has provided to us: device make, device model, operating system and the operating system version of your device, device type, screen size, orientation and battery, carrier information, the fact you accessed the ad through the Services, country, time zone and locale settings (country and preferred language), network connection type, IP address, SDK version, timestamp, network status such as WiFi, mobile advertising identifier, device event information such as crashes, system activity, hardware settings, the date and time of your request and referral URL, user-agent, the package name of the Services, IDFV, system file size, system update time, system boot time, device user name, RAM (random access memory), remaining available RAM and CPU version and information about your interaction with such ads.
This information is collected by Mintegral to serve you ads, including for the purposes of delivering interest-based advertising, behavioural advertising, cross-app or cross-device advertising, targeting or re-targeting ads, and analyzing and building profiles of users who view ads that are served by Mintegral. Once Mintegral collects this information, it becomes the controller of that information, as that term is recognized by privacy laws.
You may opt out of Mintegral’s collection of this information. For more information, please see the Choices About How We Use and Disclose Your Information heading below or visit Mintegral’s privacy policy, which you can access via the link in the next paragraph.
If you have any questions about our relationship with Mintegral, how it interacts with the Services or otherwise related to its privacy practices, you may contact Mintegral by email at: [email protected], or by mail sent to: Legal and Compliance Department, Floor 43, East Tower of Tianying Square, No.222 Xingmin Road, Tianhe district, Guangzhou, China. You may also visit Mintegral’s privacy policy at: https://www.mintegral.com/en/privacy/, for a full description of its data practices.
We use information that we collect about you or that you provide to us, including any personal information:
· To present our Services to you and to provide you with information, products, or services that you request from us.
· To improve our Services.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
· To notify you about changes to our Services.
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
· For any other purpose, with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose personal information that we collect or that you provide as described in this Policy:
· In accordance with applicable law, to a buyer or other successor, in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and users is among the assets transferred.
· To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers target a specific audience (for example, users in a specific location, or whose video library contains certain types of videos). We may make use of the information we have collected from you to enable us to display our advertisers' advertisements, to that target audience.
· To third parties to market their products or services to you, if you have not opted out of these disclosures. We only share information with third parties who commit to follow applicable privacy laws. For more information, see the Choices About How We Use and Disclose Your Information heading below.
· To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization), who commit to follow applicable privacy laws.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information or otherwise, with your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
· To enforce or apply our Terms and Conditions.
· If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or that of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable privacy legislation.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us.
You should know that we use third-party advertising companies to serve advertisements, when you use the Application. These companies may use information (not including your name, address, email address or telephone number) about your visits to the Website and other websites, in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit this link: https://thenai.org/opt-out/
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition to the information indicated above under this heading, you can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using opt-out tools created by Google Advertising, the Digital Advertising Alliance of Canada or by the Network Advertising Initiative. You may also opt out of our use of Google Analytics by visiting the Google Analytics opt-out page.
In addition, we have created mechanisms to provide you with the following control over your information:
· Tracking Technologies and Advertising. You can opt out of IDFA tracking within the iOS Settings app. For more information about tracking technologies, see the Information We Collect Through Automatic Data Collection Technologies heading above.
· Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by using the opt-out tools that are referenced above in this section.
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of the personal information you transmit to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you, or your consent.
The Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to, or through, the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any personal information on, or through, the Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that personal information. If you believe we might have any personal information from or about a child under 13, please contact us at [email protected]
YOUR CALIFORNIA PRIVACY RIGHTS
California residents have the right to receive: a) information identifying any third party company(ies) to whom Spocien may have disclosed (within the previous calendar year) personal information pertaining to you and your family for that company’s direct marketing purposes; and b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request here [email protected] with “Request for California Privacy Information” as the subject line and in the body of your message. Please be aware that not all information sharing is covered by requirements and only information on covered sharing will be included in our response. Please also note that under California law, businesses are only required to respond to a customer request once during any calendar year.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you have the right to request access to and to correct the personal information that we hold about you. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.
If you want to review, verify, correct, or withdraw consent to the use of your personal information, you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you, or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected]
Proper access and use of information provided on, or through the Services, is governed by our Terms and Conditions.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected] Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
It is our policy to post any changes we make to our Policy, on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page and/or through the Application. We include the date the Policy was last revised at the top of this page. You are responsible for periodically visiting our Website and this Policy to check for any changes.
LANGUAGE
We and you have requested and agree that this Policy and all documents related to this Policy be drawn up in English. Les parties ont demandé que le présent accord et tous les documents connexes soient en anglais.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact us at:
Privacy Officer
[email protected]
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy, please contact our Privacy Officer using the contact information listed above.