Effective Date of Current Policy: 06/07/2018
3. TRANSPARENCY/NOTICE-TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Voxer and the requirements of applicable law. Some of the ways that Voxer may collect Personal Information include:
- You may provide Personal Information directly to Voxer through interacting with the Products, participating in surveys, during events such as sweepstakes, and requesting Products, or information.
- As you navigate the Products, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
- 3.1 TYPES OF PERSONAL INFORMATION WE COLLECT
Voxer collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Products or engage in certain activities, such as creating an Account with Voxer, responding to surveys, requesting Products or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Products, request a Product demonstration, register for Voxer’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
- Registering Products. When you register with us and use the App, you generally provide us with Personal Information such as your name, email address, user name, password, phone number and other registration information. Registration with us is mandatory in order to be able to use the App. The App obtains the Personal Information you provide when you download and register for the App. If you choose to register on the Voxer Site, we will receive that registration data as well.
- Communications with Third-Parties. The Products can be used to communicate with others. When you share information, including Personal Information, it will be seen by the recipients. Voice, text and images you create and transmit will be stored on your device, the device of recipients of such communications, and on our servers.
- Contacts Data. To provide you an opportunity to automatically connect with your contacts, we may, with your permission, access and store on our servers Personal Information regarding your contacts, including their names, email addresses, phone numbers, profile image, geographic location and Facebook IDs. In addition, when you invite contacts to use our Products, we will access your address book so you can facilitate the invitation. If you send invitations to your contacts, you represent that all such contacts have consented to receive SMS from you. To better match you with your most important contacts, with your permission, we may also access and store your call and SMS log information from your device.
- Location Information. If you give the App permission to access Location data, the App will collect your GPS location at the time you send a message. A map indicating your location will be available to the recipients of the message. You can disable this feature by turning off the location function in the “Settings” menu of the App or on your phone.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Products, Sites and/or services and in any manner consistent with the policies provided herein.
- Posting on the Site. Voxer may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Voxer’s pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Registration for Sweepstakes or Contests. Occasionally, Voxer may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
- Automatic Data Collection. We may collect certain information automatically through our Apps or other Products, such as the type of mobile device you use, your mobile device’s device ID, your IP address, your mobile operating system, the type of mobile Internet browsers you use, crash information, information about the way you use the Apps or Products, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Products, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Products, and other actions taken through use of the Apps or the Products such as preferences.
- Information Submitted to Us Via Products. You agree that Voxer is free to use the content of any communications submitted by you to us via the Products, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Products. Voxer will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- Information from Other Users of the Apps and Products. We may collect Personal Information about you from other users of Voxer Products. For example, when a friend provides friend details or contact information, or indicates a relationship with you, Voxer may receive Personal Information such as your name, email address, phone number, profile image, geographic location and Facebook ID. We may use such Personal Information to determine if you use Voxer Products, and to help your contacts find you.
- Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Products through a Third-Party application, such as an App Store or Social Networking Sites (“SNS”) such as Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. If you authorize the activity, Personal Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, gender, birth date, email, profile picture, your contacts on the SNS, and their profile information and their SNS images. This supplemental information allows us to verify information that you have provided to Voxer, to facilitate messages between you and your contacts, and to enhance our ability to provide you with information about our business and Products. In addition, Third-Party service providers may provide Voxer with automatically collected data similar to the data collected automatically by Voxer, as described more fully above.
- 3.2 HOW VOXER USES YOUR INFORMATION
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- Sharing Content with Friends or Colleagues. Voxer’s Products may offer various tools and functionalities. For example, the Apps allow you to send voice messages, text messages and photos (“Communications Content”) to other users. In addition, our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Products. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Voxer or any other Third Parties for any other purpose.
- To Provide Products or Information Requested. Voxer may use information about you to fulfill requests for Products or information, including information about potential or future Products, including to:
- Communicate with other Voxer users as directed by you through use of the Apps;
- Facilitate connections between Voxer users and other Individuals in the user’s contacts data;
- Generally manage Individual information and Accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of Voxer’s Products;
- Contact you to answer requests for customer support or technical support;
- Provide you with access to demonstrations of our Products at your request; or
- Allow you to register for events.
- Marketing Voxer Products. Voxer may use Personal Information to provide you with materials about offers and Products that may be of interest, including new content or Products. Voxer may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Products to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
- Research and Development. Voxer may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Products and services or develop new Products and services. From time to time, Voxer may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the Products and services we provide. The survey responses may be utilized to determine the effectiveness of our Products, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Voxer’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
- Anonymous and Aggregated Information Use. Voxer may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Voxer’s Products, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Products. Anonymized or aggregated information is not Personal Information, and Voxer may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Voxer and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Other Uses. Voxer may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
- 3.3 COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTERNET-BASED ADVERTISING
- Cookies. Cookies are small text files placed by a web server in visitors’ computer browsers to store their preferences and for other record-keeping purposes. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Web Beacons. A (also known as a clear gif, pixel tag or web bug) is a tiny graphic with a unique identifier, similar in function to a cookie. A web beacon is on the Site and collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Mixpanel. We may use services by Mixpanel , Inc. to obtain analytics data regarding users’ interactions with our Site and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Site or Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
- 3.4 THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS
Voxer’s Products may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Products may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Products. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
- 3.5 THIRD-PARTY PAYMENT PROCESSING
We may sell subscription services through our Products. When you make purchases through the Products, we process your payments through a Third-Party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Stripe, Inc., Recurly, Inc. and SNS such as Facebook. The Third-Party application may collect certain financial information from you to process a payment on behalf of Voxer, including your name, email address, address and other billing information.
4. ONWARD TRANSFER-VOXER MAY DISCLORE YOUR INFORMATION
- 4.1 INFORMATION WE SHARE
- Helping You to Add Contacts and Helping Your Contacts to Find You. Voxer is designed to make it easy for you to find and connect and communicate with others. For this reason, your name and profile picture may be publicly shared and other users of the Products will be able to see your name and profile picture once you register directly or through a Third-Party. Other users may also provide us contact information they have about you, such as your email address, phone number or your name, which we use to determine if you use Voxer Products. If you are already use Voxer Products, then we may share your name with others so that they can add you to their contact list by choosing your name off of a list of users available via our Products. If you enable “Privacy Mode” in the App, you will no longer be searchable by other users and your information will not be shared in this way.
- Inviting Contacts. We give you an opportunity to invite your contacts to register at the Voxer Site and download the Apps and Products, and in connection with that activity you may provide us access to Third-Party contact information. When you click to invite one or more friends to join Voxer or a Service, an SMS invite is sent from you from your phone. This SMS invite may result in your phone number being shared with the invitee and in charges to you and/or your invitee.
- Communicating with Other Users. The Products can be used to communicate with others. Voice messages, text messages and photos (“Communications Content”) you send to other users may be seen by the recipients. Communications Content you create and transmit will be stored on your device, recipients’ device, and on our servers. Even if you remove this content from your device or account, copies of this User Communications Content will remain viewable on the devices of Third-Party users with whom you have communicated and will be stored on our servers for a period of time.
- Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Marketing – Interest-Based Advertising and Third Party Marketing. We use Third-Party service providers to serve advertisements (banners or links) on our behalf across the Internet. These service providers collect information about your visits to our website. This information is collected through use of a web beacon, which is industry standard technology used by most major websites. Web beacons do not collect names or contact information, but may record other information about your visit (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Voxer related websites within their networks. In addition to the information about your visits to our website, our service providers may also use information about your visits to other websites to target advertisements from Voxer. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 5 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) as required by law, such as to comply with a subpoena, or similar legal process; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Voxer policies or contracts; (v) to collect amounts owed to Voxer; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm, fraud or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- 4.2 INTERNATIONAL DATA TRANSFERS
You agree that all Personal Information collected via or by Voxer may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Voxer, you explicitly consent to the storage of your Personal Information in these locations.
5. OPT-OUT (RIGHT TO OBJECT TO PROCESSING)
- 5.1 GENERAL
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Voxer’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us at: email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
- 5.2 EMAIL AND TELEPHONE COMMUNICATIONS
We would honor “do-not-call” and “do-not-mail” requests should you request it.
- 5.3 MOBILE DEVICES
Voxer may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Voxer may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
- 5.4 "DO NOT TRACK"
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. The Voxer Site does not collect Personal Information regarding users’ online activities over time and across Third-Party websites. As such, browser DNT signals are not relevant to the Site and Products.
- 5.5 COOKIES AND INTERNET-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or https://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
6. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
Although Voxer makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Voxer is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Voxer determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Voxer will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. DATA RETENTION
8. SECURITY OF YOUR INFORMATION
Voxer takes reasonable steps to protect personally identifiable information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We keep your account information and content on a secure server behind a firewall. When you enter sensitive information (such as passwords), we encrypt that information using secure socket layer technology (SSL) while it is being transmitted. However, you should keep in mind that no Internet transmission is ever completely secure or error-free. In particular, messages sent to or from the Voxer Site and Products may not be secure. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. INTERNATIONAL USERS
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. CHILDREN'S PRIVACY
Minors should not use the Products. The Products are not directed to children under 13 years of age (or other minimum age as required by local law), and Voxer does not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at: firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s Account.
11. REDRESS/COMPLIANCE AND ACCOUNTABILITY
12. OTHER RIGHTS AND IMPORTANT INFORMATION
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Voxer will endeavor to comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Voxer or to which Voxer discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Voxer or Voxer’s Agents.
14. REVISION HISTORY