Privacy Policy
Last updated: October 31, 2022 

We care about protecting your personal information. This Privacy Policy (“Policy”) explains how our company (“we,” or “us”) collects, uses, and shares your personal information when you access or use the mobile applications (“Apps”) or any associated features, content, or pages owned or operated by us (collectively, the “Services”) that contain this Policy. This Policy does not address the privacy practices of any third parties that we do not own or control.

Please read this Policy and the Terms of Service carefully. By choosing to use our Apps or Services, you acknowledge and agree that your personal information may be used pursuant to this Policy. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you must not use or access our Apps or Services.

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Personal And Sensitive User Data

We reserve the right to update this Privacy Policy from time to time. If we make a material change to this Policy, we will strive to notify you by displaying a notice on our Services. By continuing to use the Services after the changes become effective, you are agreeing to be bound by this Policy.

Contents:

1. Personal Information That We Collect
2. How We Use Your Personal Information
3. How We Share Your Personal Information
4. Cookies and Similar Technologies
5. Marketing
6. Security
7. Access, Modification, and Deletion
8. Retention
9. Children
10. Do Not Track

11. Contact List Permission Disclosure

12. Access to Camera/Gallery/Microphone
13. Your California Privacy Rights

14. Contact Us
15. Service Providers and Partners

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1. Personal Information That We Collect

Personal information means information that, alone or in combination with other information, may be used to identify you. Personal information includes name, user name, email address, mailing address, and phone number. When you use our Apps and Platform, we may collect the following information about you:

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a) Account Information

When you use our Apps or Platform, you may register an account with us to track your progress and to sync your activity across devices. To register an account, you may be asked to provide certain personal information to us: 

• Name

• Email Address 

• Password

• Phone Number

Additional information we may solicit from you that could constitute personal information, under certain circumstances, includes certain demographic information on your location, race, ethnicity, gender and political affiliation, and may include information on your campaign and voter canvassing activities, political contributions and voter profile and history. You are solely responsible for ensuring your account information is correct and up-to-date.

b) Information From Social Media Platforms

Our Apps and Platform are not currently synced with social media platforms; so you may not, at present, create an account with us using Facebook, Google or other account credentials. Those social media platforms are sometimes authorized to provide us with your personal information, such as your name, profile picture, email address, language preference, and other information as listed in the authorization. We may pursue these account creation options at a later date.

c) Information You Provide To Us

We collect any personal information you provide to us when you use our Platform. For example, you may provide additional account information, such as your language preferences. You may also provide information when participating in surveys, forums, sweepstakes, contests, or events, such as your contact information. You are solely responsible for ensuring the information you provide to us is correct and up-to-date. You may choose to provide information on or through our Platform about your religious views, political views, and interests (which could reveal or relate to your sexual orientation or health). This and other information (such as personal health information, racial or ethnic origin, philosophical beliefs, or trade union membership, etc.) could constitute sensitive information and not necessarily personal information. We do not solicit this information from you, and it will be supplied and made available by you at your own risk.

d) Activity and Usage Data

While accessing or using the Platform, we may automatically collect information about how you interact with the Platform. Such information may include your Internet Protocol (“IP”) address, device identifier, advertising identifier, MAC address, operating system, browser type, language preferences, referring and exiting pages, crash data, location data, purchasing activity, and other data regarding your activities on the Platform. For more information, see Section 4 below on Cookies and Similar Technologies (“Tracking Technologies”).

On our Platform, you can post messages and participate in forums and discussion groups, and much more. We collect your activity across our Platform and the information that you provide, such content that you create, like posts and comments, metadata about content and messages, types of content you view or interact with, and how you interact with, features of the App that you use, the time, frequency and duration of your activities on the Platform.

e) Customer Service

We collect the personal information you provide to us when you contact us for customer service, to provide feedback, or to request information.

 

2. How We Use Your Personal Information

We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:

a) To Provide Our Services

We use your personal information to provide you with the Apps and any other services, purchases or requests in connection with the Platform. This may

include processing transactions, providing you with the requested features, syncing your data across your devices logged into your account, customer service, etc.

b) To Personalize Your Experience

We may process your information to personalize the Platform for you, to include personalized features, recommendations, and ads. For example, we use your language preferences to display the correct language inthe Platform. We also use certain information about your device (such as operating system version and screen resolution information) to optimize the display of pictures on your screen.

c) To Send You Service-Related Communications

We will use your information (such as contact information) to send you communications about your account and changes in our policies. Please note that you may not opt out of such communications, which are necessary to keep you informed about important updates about your account and the Platform.

d) To Conduct Analytics and Other Internal Purposes

We may use your personal information to conduct analytics. This can be used for quality control, internal auditing, and to measure how our Apps, Platform, and ad campaigns are performing. We also use your personal information to accumulate and report aggregate, statistical information in connection with the Apps, Platform and user activity, in order to help us operate, enhance and improve our Platform. Our analytics may involve the provision of anonymized and/or aggregate data based upon your participation on our Apps and data that you provide regarding candidate preferences, party affiliation, demographics and so on.

e) To Ensure Security of our Platform

While we are offering services on the Platform, personal information may be used for the purposes of identity verification and authentication, customer service, security protection, combatting spam, malware, and malicious activity, , and ensuring the security of the products and services that we provide to you.

f) To Conduct Research and Development

We may process your personal information to improve our Platform and help us design new products and services. When we do so, we may implement security measures and safeguards to protect the privacy of your personal information. For example, we may institute technical safeguards or administrative safeguards, such as restricting access to personal information to only those who need access to conduct the research and development functions.

g) To Promote Our Services

We use your personal information for our marketing activities. For example, we may conduct targeted marketing and send you information about our and our products and about Platform events, and candidate forums, campaigns and electoral news and studies that may be of interest to you.

h) To Maintain Legal and Regulatory Compliance

Our Platform is subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, and to manage risk as required under applicable law.

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3. How We Share Your Personal Information
We may share your personal information in the following circumstances.

a) Affiliates

We may share your personal information within our corporate organization to facilitate the delivery of services on our Platform; however, we will require that your personal information still be handled in the manner describe herein.

b) Third-Party Service Providers

We may use third parties to perform certain functions on our behalf to provide you with services on the Platform such as:

    ● [to process payments and complete transactions you request, such as payments for any subscription service, which would be processed by Apple (App Store) or Google (Google Play Store); ]

    ● to process and store data, including your personal information; 5

    ●  to deliver ads to you based upon information that we provide;

    ●  to provide security for our Platform; and

    ●  to conduct market research.

We have agreements with third-party service providers in place to ensure they use adequate safeguards when processing your personal information.

c) Merger, Acquisition, or Other Business Transaction

We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of our Apps or Platform, or in connection with a merger, acquisition, consolidation, restructuring, or the sale of substantially all our interests and/or assets (i.e., a bankruptcy proceeding). We shall require the subsequent owner, co-owner, or operator in possession of your personal information to continue to be subject to this Privacy Policy; otherwise, we shall request that they obtain the necessary consent from you.

d) Legal Obligations and Safety

We may disclose your personal information if it is reasonably necessary to:

    ●  Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);

    ●  Comply with valid requests or investigations by public authorities;

    ●  Comply with applicable laws or regulations;

    ●  Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise;

    ●  Protect our legitimate interests, including legal interests;

    ●  Protect the security or integrity of the Platform; or

    ●  Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.

We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.

e) With Your Consent

We may transfer your personal information for other reasons after obtaining your consent.

To use less information that’s connected to individual users, in some cases we de-identify or aggregate information. We might also anonymize it so that it no longer identifies you. We use this information in the same ways we use your information as described in this section.

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4. Cookies and Similar Technologies (“Tracking Technologies”)

a) What are cookies and tracking technologies?

Cookies are small data files, typically of letters and numbers, that are placed by a web server on your device. We and companies we work with may use cookies and similar technologies, including pixel tags, web beacons, mobile analytics features, and mobile identifiers (collectively, “tracking technologies”) to collect information for many reasons, such as to keep you logged in to your account, remember your preferences and settings, analyze usage of our Platform, measure the performance of our Platform and advertising campaigns, and ensure security on our Platform. Some of the functions performed by tracking technologies are strictly necessary for us to be able to offer you our Platform, while others provide us with valuable insight about how we can improve or

market our Platform.

b) What types of tracking technologies do we use?

We use the types of tracking technologies described below on our Platform:

Types of Tracking Technologies

Description

Strictly Necessary

Some of the tracking technologies we use are necessary to provide our Platform to you. For example, they help you: navigate from page to page; stay logged into your account; and support and enable security features. Without such tracking technologies, some of our Platform cannot be provided to you.

Functional Functional tracking technologies collect information about how you use our Platform,

provide you with certain functions on our Platform, and remember your preferences.

Analytics, Performance and Research

These tracking technologies help us understand how well our Platform are doing. They collect information about your use and interaction with our Platform so that we can continue to improve and expand our Platform.

Marketing

Marketing tracking technologies allow us to collect information about your interactions with our marketing activities, such as parts of our website and our emails. They help us measure performance of our Platform and advertising campaigns.

c) How to manage tracking technologies

We use third-party tracking technologies that allow us to automatically collect information through our Platform that can recognize your device both when it visits our Platform and when it visits other websites or mobile apps. We encourage you to check the websites of any third-party tracking technologies

providers for more information about how they use the information they collect.

Below we describe how you can manage tracking technologies on our Platform:

1) Through Your Browser

You can enable, disable or delete tracking technologies via your browser settings. To do this, follow the instructions provided by your browser, usually

located within the “Help”, “Tools” or “Edit” settings of your browser or mobile device. Please be aware that if you set disable tracking technologies on your browser, you may not be able to access secure areas of the Platform and parts of the Platform may also not work properly (e.g., preferences, referral

links).

Many browser manufacturers provide helpful information about cookie management, including, but not limited to:

    ●  Google Chrome

    ●  Internet Explorer

    ●  Mozilla Firefox

    ●  Safari (Desktop) or Safari (Mobile)

    ●  Android Browser

    ●  Opera

If you use a different browser than those listed above, please refer to your

specific browser’s documentation or check out http://www.allaboutcookies.org/browsers/index.html to learn more about different browsers. You can also find out more information about how to change your browser cookie settings at www.allaboutcookies.org.You may also opt out of cookies within web browsers by visiting industry-created opt-out platforms such ashttp://networkadvertising.org/managing/opt_out.asp and/or https://optout.abou tads.info/?c=2&lang=EN, or if you are in the European Union, http://www.youronlinechoices.eu/. You can also click on the AdChoices logo within an advertisement (where available).

2) Through Your Mobile Settings

You may be able to control or limit mobile tracking technologies in your mobile

device settings. Please follow the instructions provided by your mobile device, usually located in “Settings” of your mobile device. Many mobile device manufacturers provide helpful information about how to do this:

    ●  Apple

    ●  Google/Android

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit

ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).

Additionally, please visit http://aboutads.info/appchoices to learn about and download the Digital Advertising Alliance’s free consumer choice app, AppChoices, which allows you to opt out directly from companies listed in the

app. Where applicable, the AppChoices app also allows California residents to submit requests to opt out of the sale of personal information to the companies

listed in the AppChoices app under the California Consumer Privacy Act (CCPA).

3) Through Third Parties

Within Section 15 below, which lists our service providers and partners, as well as links to each third party’s website for information about how they use tracking technologies to collect and use your information, and how you may be able to

opt out of tracking.

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5. Marketing

We may use your personal information to send you messages about new products and services, events, or other information that may be of interest to you, whether through email or other methods. If you do not wish to receive such information, you can change your account settings or click the “unsubscribe” button in email communications. Please note that you will not be able to opt out of receiving transactional communications; otherwise, you may miss important information about your account or the Platform.

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6. Security

We take the security of personal information seriously. We adopt standard practices in the internet industry to protect your personal information from unauthorized access, disclosure, use, alteration, and corruption or loss. We shall take all reasonable and feasible measures to protect your personal information. We shall do everything possible to take appropriate technical measures to ensure the accuracy and timely update of the personal information collected about you.

Please understand that due to the nature of the internet industry, it is impossible to ensure that systems are 100% secure. You should understand that the systems may encounter issues due to the factors beyond our control, such as malicious actors. Although the security of your personal information is our highest priority, there will always be a risk that your Personal Information gets compromised. We also depend on you to keep your account information and other personal information secure by keeping your password confidential and taking precautions to keep others from accessing your account.

 

7. Access, Modification, and Deletion 

You may make changes to the information you provided in conjunction with your account by logging in to your account and changing the applicable information. We offer you a variety of tools to view, manage, download and delete your information below. You can also manage your information by visiting the settings of the products you use. If you request that we delete your account or content, it may take up to 90 days to delete your information after we begin the account deletion process or receive a content deletion request. After the information is deleted, it may take us up to another 90 days to remove it from backups and disaster recovery. If you are not able to make modifications by logging into your account, or if you wish to terminate and delete your account, you may contact us at info@mybalbo.com. Following receipt of a request from you, we will take reasonable steps to make changes or delete your information as required under the applicable law.

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8. Retention

In general, we keep your information for as long as necessary to achieve the purposes stated in this Policy or to comply with the applicable law. Otherwise we will try to delete your personal information upon your request or when we no longer need it for the purposes it was originally collected, although we reserve the right to retain such information indefinitely for the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes. We will not delete any personal information that also relates to other individuals, unless such other individuals also wish to delete their personal information at the same time.

We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.

    ●  Account information: We will retain information associated with your account as long as your account remains active or as necessary to provide you with the requested services.

    ●  Information collected from tracking technologies: we generally retain such information for as long as necessary for usage analytics, the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.

    ●  Marketing data: Any contact information you provide to us for marketing purposes, such as your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. If you unsubscribe, we will add your contact information to our do-not-contact list to respect your unsubscribe request.

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9. Children

Our Platform is not intended for use by children under the age of thirteen (13). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. If you are under the age of sixteen (16), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of sixteen (16), please contact us immediately according at info@mybalbo.com.

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10. Do Not Track

Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit “Do Not Track” (“DNT”) signals. Since uniform standards for DNT signals have not been adopted, we currently do not process or respond to DNT signals on our Platform.

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11. Contact List Permission Disclosure

When a User access the app, we might ask permission for access of contact number of users present in their mobile device. These details are used to invite users added in the mobile device to our community, or to add connections with mutual users of the device and myBalbo community. 

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When a user connects their myBalbo account to their device’s contact list:

• myBalbo will access and upload the names, phone numbers in their contact list.

• myBalbo will recommend other myBalbo users based on a user contact list when they initially register for an account. You can also receive recommendations from myBalbo under the Discover People page under Settings.

• A user contact list is periodically synced and securely stored on our servers. Contact synching can be turned off under the user’s device settings.

• Your device’s contacts will only be visible to you.​

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12. Access to Camera/Gallery/Microphone

Users of the app can upload Audio, Photos, Videos and capture images/videos in the app. To do so, the mobile app will access the Camera, Microphone and Gallery of the Device. We take consent from users before accessing the Camera, Gallery / SD card of the Device, and Microphone.

 

13. Your California Privacy Rights
If you live in California, you can ask us for a list of third parties we share your

Personal Information with for marketing purposes.

California law permits California residents to ask us for a notice that identifies the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us with your name, account information, and proof of California residence at info@mybalbo.com with the subject line “My California Privacy Rights.”

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14. Contact Us
For any questions regarding our Privacy Policy or our privacy practices, please contact us at info@mybalbo.com. 

 

15. Service Providers and Partners

We use third parties to help us operate and improve our Platform. These third parties assist us with various tasks, including hosting and maintenance, on- going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Platform.

a) Advertising networks and their partners

The below companies assist us by providing services relating to advertising and marketing. If you reside in the European Economic Area (“EEA”), the advertising networks, analytics providers, and other companies listed below request your consent to collect or receive device information from our apps on your browser or device for advertising purposes, including personal and non- personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, the inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery,

reporting, and optimize targeted ads. Ad identifiers are non-permanent device

identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). For more information on how to opt-out, please see “How To Manage Tracking Technologies” in section 4(c). In addition, certain advertising networks that act as data processors upon our instructions are independent data controllers in respect of your personal information and you can learn more about how each handles your data or provides opt-outs by accessing their respective privacy notices.

b) Analytics and other service providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical

information for supporting business analysis and operations, business intelligence, product development, improving the Platform, personalizing

content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

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AWS

AWS is cloud computing services provided by Amazon Web Services, Inc.

(US).
Privacy Policy: https://aws.amazon.com/privacy/

Google Analytics

Google Analytics is analytics service provided by Google Inc. (US) Privacy Policy: https://policies.google.com/privacy

Agora

Agora is a video conferencing service provided by Agora Lab, Inc. (US) Privacy Policy: https://www.agora.io/en/privacy-policy/
Data Dog
Data Dog is an infrastructure monitoring tool provided by Datadog Inc. (US) Privacy Policy: https://www.datadoghq.com/legal/privacy/

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