any Information you provide to us.
The use of our services may involve the collection and use of your Information (as defined in the “The
Information We Collect and How We Collect It” section below) on our services (including our websites and
mobile applications). It is important for you to understand how this happens and how you may control it,
By using our services, you agree that we may collect, use and share your Information in accordance with
privacy guidance applicable to their use. Such service-specific privacy guidance are incorporated into
the context requires otherwise.
party services (including any third party websites) that you may access through our services; or (ii) by
other companies and organisations who advertise their services on our services.
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing our services, we collect, store and use the following Information relating to you:
" is Personal Information and Non-Personal Information;
" is any information or combination of information that relates to you, and
can be used to identify you. Personal Information may include the following:
• information you make available to us when you open an account or use our services, such as your name,
telephone number, email address and credit card details;
• information which you make available to our services as you use them, including Shared Information you
make available to others through our services and information you store using our services;
• Shared Information that others using our services make available about you, such as information
contained in posts they make and communications they make to you and others using our services;
• information we collect as you use our services, such as certain Location Data, Log Data and public
" is information that we collect regarding your location (when you use a
location-enabled service), including:
• the location of your device when you use our services, such as from the GPS, WiFi, compass,
accelerometer or other sensors in your device;
• the IP address of the device or internet service you use to access our services,
• other information made available by you or others that gives an indication as to where you are or have
been located, such as account information that indicates where you are located and Shared Information
you or others post indicating your location, such as any geotag information that is embedded in any
photos you make available to us; and
• if you have provided us with your location data previously and would like us to delete such existing
location data, you may be able to do so via our services.
" is technical information that is automatically collected by us when you use our
• technical information such as your mobile carrier, configuration information made available by your
web browser or other programs you use to access our services, your IP address and your device’s version
and identification number,
• information about what you have searched for and looked at while using our services, such as web
search terms used, social media profiles visited and details of other information and content accessed
or requested by you in using our services;
• information about what apps and other software you have used and how you have used them;
• information about communications you have made using our services, such as the people you’ve
communicated with and the time, data and duration of your communications; and
• metadata, which means information related to items you have made available through our services, such
as the date, time or location that a shared photograph or video was taken or posted.
" is any information that relates to you but from which it is not
practicable to directly or indirectly identify you, including Personal Information in aggregated,
anonymised or pseudonymised form.
" is information about you or relating to you that is voluntarily shared on
our services, including postings that you make on our services (including your public profile, the lists
you create), any postings from others that you re-post and including Location Data and Log Data
associated with these postings. Shared Information also includes information about you (including
Location Data and Log Data) that others who are using our services share about you.
HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
• to provide our services to you;
• for customer service, security, fraud-detection, archival and backup purposes in connection with the
provision of our services;
• to provide you with advertising (as discussed in more detail under the “Advertising” section
• to better understand how you access and use our services, for the purposes of trying to improve our
services and to respond to customer desires and preferences, including language and location
customisation, personalised help and instructions, or other responses to your and other customers’ usage
of our services;
• to help us develop our new services and improve our existing services;
• to assess the effectiveness of and improve advertising and other marketing and promotional activities
on or in connection with our services;
• for the purposes of software verification or administering software upgrades; and
• to allow you to participate in surveys and other activities about our products and services.
Please note that for the purposes of seeking to provide our users with a better experience, to improve
our services or otherwise where you have consented, Personal Information collected through one of our
services may, subject to user privacy controls (where available), be used by our other services
(including in an aggregated or individualised manner).
For example, Personal Information collected during your use of one of our services may be used to
suggest particular content that can be made available to you on another service or be used to try to
present more relevant advertising to you in another service. You may also from time to time ask us to
migrate or export your Personal Information contained in one of our services to another of our services,
where such migration option is available.
If any of your Personal Information comprises Your Content (as defined in the Terms of Service ), we and
with the “Your Content” section of the Terms of Service .
Our service-specific privacy guidance may more particularly describe how we use Personal Information
within the relevant services.
As noted under the "Use of your device by our services" section in the Terms of Service , we may require
access to or use of your Personal Information within your device in order to provide our services to
you. Any Personal Information that we use or access within your device will be treated in accordance
SHARING OF YOUR PERSONAL INFORMATION
transfer your Personal Information to any other third parties for their processing for any purposes.
We and our affiliate companies may share your Personal Information within our group of companies and
with joint venture partners and third party service providers, contractors and agents (such as
communication service providers who send emails or push notifications on our behalf, mapping services
providers who assists us and you with location data, analytics partners who assist our business, and
advertising partners on our serices). In addition, we may allow such third parties to collect your
Personal Information across our services. In each case, we permit such sharing and/or collection for the
purposes of: (i) providing our services to you; (ii) assisting us in carrying out the purposes set out
under the “How We Use Your Information” section above; (iii) carrying out our obligations and enforcing
helping us better understand and improve our services. These third parties may be located, and use and
store your Personal Information, outside of your jurisdiction for these purposes.
Where we permit any third parties to collect and use your Personal Information in accordance with the
above paragraph, we will use reasonable efforts to ensure that such third parties only use your Personal
give them, including any appropriate confidentiality and security measures that we implement.
You consent to the third party use, sharing and transfer of your Personal Information (both inside and
outside of your jurisdiction) as described in this "Sharing of your Personal Information"
As we continue to develop our business, we or our affiliate companies may be acquired by a third party
or re-organise our group structure. In these circumstances, it may be the case that your Information is
transferred within our group and/or transferred to a third party who will continue to operate our
be notified to you. The party to which your Personal Information is transferred may be located, and use
your Information, outside of your jurisdiction.
You agree that we or our affiliate companies may be required to retain, preserve or disclose your
Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to
comply with a court order, subpoena or other legal process; (iii) in response to a request by a
government authority, law enforcement agency or similar body (whether situated in your jurisdiction or
elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or
regulations. You also agree that we or our affiliate companies may need to disclose your Personal
property or safety, or the rights, property or safety of our affiliate companies or other users of our
A WORD ABOUT SHARED INFORMATION
A number of our services enable Shared Information to be shared publicly with all users of that service
and not just your contacts. Our social media services in particular are primarily designed to help you
share Shared Information with the world, so Shared Information can be broadly and instantly transmitted
and will remain public for as long as you do not delete it (and even after you delete Shared
Information, it may still be separately cached, copied, or stored by, or remain public through, other
users or third parties who are not affiliated with and not controlled by us).
Please consider carefully what you post and communicate through our services.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use our services, we may use your Information to send you emails, newsletters or push
notifications to your device. If you no longer wish to receive these communications, you can do so by
following the unsubscribe instructions in the emails we send to you, opting out of notifications at the
device level (if available) or contacting our Privacy Officer.
We may from time to time send you service-related announcements when we consider it necessary to do so
(such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these
service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain Personal Information, such as information about your race or ethnic
origin, religious or philosophical views or personal health, is characterised as “sensitive” and is
subject to stricter regulation than other personal information. Please note that content and information
that you input to our services, such as photographs or information about your school or social
activities, may reveal your sensitive Personal Information to others.
We urge you to consider whether it is appropriate to communicate sensitive Personal within our services.
You consent to all processing of sensitive Personal Information for the purposes and in the manner
Please note that we do not use your sensitive Personal Information for the purpose of serving
advertising to you.
THIRD PARTY SERVICES ON OUR SERVICES
Our services may include, or they may link you to, social media or other services (including websites)
provided by a third party. For example:
• you may be able to share content on our services using services provided by third parties. The third
parties who provide such services may be able to collect your Information and Personal Information
(including your Log Data), and may set cookies on your computer to enable such third party services to
function properly; and
• we may (whether in advertisements or otherwise within our services) provide you with links that allow
you to access third party services or websites.
These third party social media or other services may be hosted by the relevant third party or us. Your
use of any such third party services (whether social media services or otherwise), including any
Personal Information you provide to such third parties, are subject to the relevant third party’s own
review their terms carefully.
offered by or information practices of any third parties, and we bear no liability for any third party
use of any Information provided by you to them.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the
server on which your Personal Information is used and stored may not be in your jurisdiction.
You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction)
We use a variety of security technologies and procedures for the purpose of preventing loss, misuse,
unauthorised access or disclosure of Information.
In some of our services, we will use encryption technology (such as SSL) to protect certain sensitive
Information provided by you to us. Please be aware that despite our efforts, no data security measures
can guarantee 100% security at all times. Our systems and the communications networks through which you
access our services may be subject to security breaches and failures which are due to circumstances
beyond our reasonable control.
RETENTION OF YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal
Information” section above), we will only retain your Personal Information for so long as is necessary
to fulfill the purposes as set out under the “How We Use Your Information” section above.
Subject to applicable laws and regulations, you may have the right to request to receive a copy of and
make any corrections to your Personal Information which we hold, or to request that we delete any of
your Personal Information that is stored by us. You may direct such request to our Privacy Officer. We
will respond to all requests made to our Privacy Officer under this “Retention of your Personal
Information” section within 60 days.
In addition, within some of our services, we may offer you options to amend or delete, and/or change how
we and the public can view and/or access, your Personal Information and/or Shared Information within
those services – in which case, please log into your account with us within the relevant service and
make the appropriate changes.
Should your account be terminated by you or us for any reason, we will (subject to the above paragraph)
take steps to ensure that your Personal Information is no longer available through our services, or
otherwise used by us, within a reasonable period of time (subject to technical limitations) after such
account termination. However, it is important to note that communications made by you using our services
may put your Personal Information in the hands of third parties that we cannot control – for example, if
you have previously made your Personal Information public via our services. In some instances, we may
not be able to delete your Personal Information and/or Shared Information from our services or systems –
in which case we will (where reasonably practicable) let you know why we are unable to do so.
How to contact us
If you have any questions or wish to exercise your rights as a data subject established in this privacy notice, please contact us at firstname.lastname@example.org