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LipMemo Privacy Policy

Last Updated: April 21, 2021

Welcome to Lip Memo (the "Platform"). The Platform is provided or controlled by Lip Memo Ltd., a corporation registered in the United States (“Lip Memo”, “we” or “us”). We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you are accepting and consenting to the practices described in this policy.

 

The Types of Information We Collect

We may collect and use the following information about you:

  • Information you give us. You may give us information about you by accessing or using our Services or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register for and/or use the Platform, such as your customer profile, photographs, information about your device, your browsing records, the comments you make on our Platform (including any Virtual Items (as defined in the Terms of Service) you contribute to any user-generated content), as well as account and billing details, including but not limited to, your Apple, Google or Windows account, PayPal or other third-party payment channel account where required for the purpose of paying or withdrawing cash. The information you give us may include your name, State ID number, address, email address, social media login details, telephone number, credit or debit card information. It also includes information that you give to us, such as user-generated content and video content that you may choose to upload or broadcast on our Platform. It also includes information in or about the content you provide, such as the location of a photograph or the date a photograph was created. It further includes collection and use of your face landmarks or face contour for creation of face stickers, so we can achieve the video effect that you might like, however, we do not store or share any such information.
  • Information you choose to share from your social networks. If you choose to link the Platform to your social network or public forum account (such as Facebook or Google), you may provide us or allow your social network to provide us with information from your social network or public forum accounts, including your contact list. This data may include your use of the Platform on such public forums and/or social networks. For further information as to how and for what purpose the social network provider processes your data, please see their privacy policies.
  • Technical information we collect about you. We automatically collect certain data from you, including IP address or other unique device identifiers such as Android advertising ID, Cookies (as defined below), mobile carrier, time zone and locale setting, operating system and platform and information regarding your use of the Platform. We may also collect information about linking your contact or subscriber information with your activity across our Platform or by linking your activity on our Platform across all your devices using your email or social media log-in details.
  • Behavioral information we collect about you. We also collect information regarding your use of the Services, e.g. your comments on our Platform or any other user-generated content and video content that you generate through and broadcast on our Platform. In addition, we link your contact or subscriber information with your activity on our Platform across all your devices using your email or social media log-in details. We collect engagement scores (“likes”, comments, repeated views) and relate users based on your behavior. Finally, we collect opt-ins and communication preferences.
  • Location data. When you use the platform on a mobile device, we may collect information about your location, including location information based on your SIM card, IP address. With your permission, we may collect Global Positioning System (GPS) data and mobile device location information. We may use such information to provide you with location-based services, such as advertising and other personalized content. If you do not wish to share your GPS or mobile device location information with us, you can switch off location information functionality on your mobile device. If you do not wish to share your content on the Nearby page, you can choose to not appear on the Nearby page in Privacy settings.
  • Message. We collect and process information you provide, including any personal information, in the context of composing, sending, or receiving messages (that means the content as well as information about when the message has been sent, received and/or read and the participants of the communication) through our Service's messaging functionality.
  • Metadata.When you upload a video to the platform (“User Content”), you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your video the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the video to your user account. Metadata will further consist of additional data that you chose to provide with the video, e.g. any hashtags used to mark keywords to the video or comments.
  • Information from third parties. We may receive information if you use any of the other websites we operate or other Services we provide. We may also receive information from third parties (such as advertising networks and analytics providers) and from other sources, including business directories and other commercially or publicly available sources.
  • Your phone contacts. You can choose whether to find other users of the platform through your phone contacts. If you choose to find other users through your phone contacts, we will access and collect your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the Platform by matching them with existing users of the Platform.

Cookies

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to enhance your experience on the platform. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

We use the following Cookies:

  • Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.
  • Analytical/performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality Cookies.These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with service providers and business partners for this purpose.

If for any reason you wish to not take advantage of Cookies, you may disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of the Platform and we will no longer be able to offer you personalized content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.

"Do not track" signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to "do not track" signals in your web browser. 

How We Use Your Information

We use your information to fulfill and enforce our terms and policies, to improve and administer the Platform and allow you to use its functionalities. We also use your information to, among other things, show you suggestions, promote the Platform, and serve you targeted advertising.

We will use the information we collect about you in the following ways:

  • To administer the Platform (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee the Platform’s stability and security) and to solicit your feedback;
  • To allow you to participate in interactive features of the Platform, when you choose to do so;
  • To personalize the content you receive and provide you with tailored content that will be of interest to you;
  • To improve and develop our Platform and conduct product development;

To measure and understand the effectiveness of the advertising we serve to you and others;

  • To provide you with services based on the country settings you have chosen, such as advertising and other content that is related to the country settings;
  • To make suggestions and recommendations to you and other users of the platform about goods or services that will interest you or them;
  • To allow other users to identify you via the "Find other friends" function as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Services;
  • To provide you with your profile information to send to anyone you choose and to enable you to participate on the Platform and interact with other users;
  • To make your information available to other users in accordance with the privacy settings you chose for the respective information;
  • To show you content that is similar to content you liked or interacted with (by commenting and/or watching the content), content from your region as well as content from users you follow;
  • To show you advertisements that are relevant to you;
  • To promote the Services and use information that you give to us, such as User Content and video content that you can choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform;
  • To understand how you use the Platform, including across your devices;
  • To infer additional information about you, such as your age, gender, and interests;
  • TO enable our messenger service to function;
  • To help us detect abuse, fraud, and illegal activity on the Platform;
  • To notify you about changes to our Services;
  • To communicate with you.
  • To provide you with user support;
  • To enforce our terms, conditions and policies;
  • To receive payments from you and/or make payments to you in accordance with the Diamond and Flame provisions set out in the Terms of Service.

It is in our legitimate interests to promote the platform, and we may use information that you give to us, such as user-generated content and video content that you may choose to upload or broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform. It also includes information in or about the content you provide, such as the location of a photograph or the date a photograph was created. It further includes collection and use of your face landmarks or face contour for creation of face stickers, so we can achieve the video effect that you might like, however, we do not store or share any such information.

 

How We Share Your Information

We are committed to maintaining your trust, and while we do not sell personal information to third parties, we want you to understand when and with whom we may share the information we collect for business purposes (in or outside your country).

We share the personal data we collect listed above with service providers and business partners to help us perform business operations and for business purposes, including research, payment processing and transaction fulfillment, database maintenance, administering contests and special offers, technology services, deliveries, email deployment, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing.

We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use Your Information”).

We may share your information with law enforcement agencies, public or tax authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process or request (including tax and related reporting requirements);
  • enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We may also disclose your information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets; or
  • if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

We may also share information for other purposes pursuant to your consent or with your further direction.

Your Rights

  • You may have the right to access and review personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at feedback@lipmemo.com. We will respond to your request consistent with applicable law.

The Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

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;
  • legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • our legitimate business purposes; and
  • disputes or potential disputes.

After you have terminated your use of our Services, we can store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

Information Relating to Children

The platform is not directed to children under the age of 13 years of age. Users under the age of 13 are not permitted to use the platform or register for an account on the platform. If we become aware that personal data has been collected from a person under the age of 13, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a child under the age of 13, please contact us at feedback@lipmemo.com.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at feedback@lipmemo.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

Changes

We will generally notify all users of any material changes to this Policy through a notice on our Platform, however, you should look at this Policy regularly to check for such changes. Your continued access to or use of the 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 the Services.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to:

  • Lip Memo Ltd.
  • Address: ADD ADDRESS
  • Email Address: feedback@lipmemo.com

Supplemental Terms – Jurisdiction-Specific

United States.

  • Access/Delete Information. You may submit a request to access or delete the information we have collected about you by sending your request to us via the methods provided in the contact section above. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have.
  • Sharing for Direct Marketing Purposes (Shine the Light). If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To request a notice, please submit your request to feedback@lipmemo.com.
  • Content Removal for Users Under 18. Users of the Platform who are California residents and are under 18 years of age may request and obtain removal of User Content they posted by emailing us at feedback@lipmemo.com. All requests must be labeled "California Removal Request" on the email subject line. All requests must provide a description of the User Content you want removed and information reasonably sufficient to permit us to locate that User Content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.

India. If you are using our services in India, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Privacy Policy, the following terms shall prevail.

  • The security of your personal data. The personal data shared by you for the purposes of the services is our highest priority and would be safeguarded in accordance with the policies and systems adopted by us.
  • Data retention. We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.

Information relating to children. The platform or mobile application versions are not directed at persons under the age of 13. Users under the age of 13 are not permitted to use the platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 13, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a person under the age of 13, please contact us at feedback@lipmemo.com.