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Last updated: [Oct 14, 2024]
This Privacy Policy applies to you when you access or use Dots and our related websites, services, applications, products and content (collectively, the “App”). The App is operated by Dot Passion LLC (“Dot”, “we”, “our” or “us”).
This Privacy Policy explains our practices concerning the personal data we collect from you when you use the App and rights that you may have under the privacy laws that apply to you. “Personal data” means information that identifies or can reasonably be used to identify you, and includes the term “personal information”, “personal data” or any similar term as these terms are defined under the privacy laws that apply to you. If you reside in California, please also see our “California Notice at Collection”further below, and our CaliforniaConsumer Privacy Act (CCPA) Privacy Policy.TheApp is not directed at children under the age of 13. If you believe that wehave personal data about or collected from a child under the relevant age,please contact us through the contact information disclosed in the “Contact”section below.
The App is not directed at children under the age of 13. If you believe that wehave personal data about or collected from a child under the relevant age,please contact us through the contact information disclosed in the “Contact”section below.
What personal data dowe collect, use and disclose about you?
We collect and use personal data you give us when you create an account and upload content to the App. If you refuse to provide certain personal data, it may denyyour access to the related services or features we provide for you.
The types of personal data we collect, use, process and disclose (where applicable)are as follows:
Your Registration and Profile Personal data. We process the content and personal data you generate and view on the App, including preferences you set (such as choice of language), push notification settings, as well as photographs, audio content and videos you upload or create, comments / mentions you make.
“User Content and Behavioral Personal data. We process the content and personal data you generate and view on the App, including preferences you set (such as choice of language), push notification settings, as well as photographs, audio content and videos you upload or create, comments / mentions you make (“User Content”). We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content.If you apply an effect to your User Content, we may collect a version of yourUser Content that does not include the effect. We may collect personal data about the images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of any face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this personal data to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations.
If with your permission, we may access text or links found in your device’s clipboard. For example, if you choose to initiate content sharing from a third-party app, or choose to paste content from the clipboard into the App, we access this personal data stored in your clipboard in order to fulfill your request.
If with your permission, we may also access your device storage (including your photo album, video album, and other document libraries in your device) for thepurpose of enabling you to save any images or videos created on the App into your device.
We collect personal data regarding your use of the App, e.g., how you engage with the App, how you interact with content we show to you, the ads you view, videos you watch and problems encountered, the content you like, the content you save to “Collection”, the users you follow and how you engage with your followers.
We also infer your preferences and your interests to personalize content for you.We process personal data about your followers, the likes you receive and responses to content you upload, to promote your User Content to other users and to explore whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this personal data to serve personalized advertising and to tell you about new services and opportunities.
Personal data from Third Parties. You may choose to disclose certain data to us through third parties or we may collect such third-party data automatically with your consent. For example, if you choose to register or use the App using a third-party social network account login service or details (e.g., Facebook, Twitter, Google), you will provide us or allow such third party to provide us with your username, phone number, email address, public profile, and other possible personal data related to such account. If you link your App account to another service, we may receive personal data about your use of that service.
TechnicalPersonal data we collect about you. We collect certain technical personal data, including your IP address, user agent, mobile carrier, time zone settings, language settings, model and manufacturer of your device, internet service provider, device system, network type, deviceIDs (e.g., Android ID, Identifier for Advertisers (IDFA), Open AdvertisingIdentifier (OAID), IMEI), your screen resolution and operating system, CPU version, OS Version and App Version, SDK version, app and file names and types, keystroke patterns or rhythms, battery state, personal data on other installed apps, audio settings and connected audio devices, and other technical data regarding about your device, its software, your network, and how you interact with the App. Where you log in from multiple devices, we will be able to use your profile personal data to identify your activity across devices. We may also associate you with personal data collected from devices that you have previously used to log in to the App, other than the device that you presently use to log in to the App.
ChatHistory Customer Service. We collect your chat histories with our customer service, which may include personal data, for the purpose of improving our customer service.
Location.We collect personal data about your approximate location, including location based on your SIM car dand/or IP address. With your permission, we may also collect precise location data (such as GPS). The personal data collected will be used for content recommendation, content creation, edit of user profile, and safety and risk management.
Personal data in your Contact Book. You can choose whether to find other users of the App using our 'SuggestedAccounts' function. This functionality allows you to see which of your friends from either your phone's contact list or Facebook friends list is using the App and offers you the option to follow them and receive push notifications in relation to their activities. You can also use this function to invite your contacts to join you on the App. We will use the contact personal data you have for that person, either from within your phone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third-party message (such as WhatsApp, Facebook (including Facebook Messenger)or Twitter) inviting them to view your App profile.
Proof of your identity or age. We sometimes ask you to provide proof of identity or age in order to use certain features, such as livestream or verified accounts, or in other instances where verification may be required.
How we use your personal data
We may use the personal data we collect about you to:
•improve, administer, promote and develop the App;
•serve you targeted advertising;
•create your App account and set up your App profile;
•enable one-tap login and third-party login;
•notify you about changes to our service;
•provide you with user and account support;
•personalize the content you receive and provide you with tailored content that will be of interest to you;
•enable you to share User Content and Location and interact with other users;
•enable our messenger service to function if you choose to use this function;
•enable you to participate in the virtual items program;
•communicate with you;
•help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the App;
•ensure your safety and security including reviewing user content, messages and associated metadata for breaches of our policies and other inappropriate content;
•ensure content is presented in an effective manner for you and your device;
•improve, promote and develop the App and promote popular topics, hashtags and campaigns on the App;
•carry out data analysis and test the App to ensure its stability and security;
•allow you to participate in interactive features of the App;
•enable you to socialize on the App, for example, by allowing other users to identify you on the App or through their phone contacts;
•ensure that you are old enough to use our App (as required by law);
•provide you with personalized advertising and community news, by sending an email, subject to applicable laws;
•provide you with location-based services (where available);
•inform our algorithms;
•enforce our terms, conditions and policies;
•administer the App including troubleshooting;
•facilitate sales, promotion, and purchase of goods and services and to provide user support;
•exercise our legal rights, defend and advance our legal interests, comply withour legal obligations (such as under data protection laws), and identify or protect against fraudulent, harmful, damaging or illegal activity; and
•prepare for or give effect to a reorganization, restructuring, merger, acquisition, or whole or partial sale or transfer of our business or assets.
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way.
Parties to whom we disclose your personal data
Your data may be disclosed to the following types of third parties:
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
Parties with whom we share your personal data
Your data may be shared or be transmitted to the following selected third parties:
ThirdParty Social Media Operator
If you choose to register to use the App using a third-party social network account login service or details (e.g., Facebook, Twitter, Google), certain personal data such as your app ID, access token and the referring URL may be transmitted to the relevant social network. If you choose to allow a third-party service to access your account, certain personal data about you maybe transmitted to the third party. Depending on the permissions you grant, the third party may be able to obtain personal data of your account and other personal data you choose to provide.
Where you opt to share content on other social media apps, the video, username and accompanying text will be shared on that app or, in the case of sharing via instant messaging apps such as WhatsApp, a link to the content will be shared.
ServiceProviders
We may provide personal data and content to service providers who support our business, such as consultants, accounting firms, auditors, cloud service providers and providers of content moderation services to ensure that the App is a safe and enjoyable place and service providers that assist us in marketing the App.
We may also provide personal data and content to providers of SDKs, such as AmazonWeb Services, Facebook, Twitter, and Google.
Analytics providers
We may use analytics providers to help us in the optimization and improvement of the App. Our third-party analytics providers also help us serve targeted ads.
Advertiser sand Advertising Networks
We may disclose personal data to advertisers and third-party measurement companies to show how many and which users of the App have viewed or clicked on an advertisement. We disclose your device ID to measurement companies so that we can link your activity on the App with your activity on other websites; we then use this personal data to show you ads which may be of interest to you.
OurCorporate Group
We may also disclose your personal data to other members, subsidiaries, or affiliates of our corporate group, to provide the App including improving and optimizing the App, preventing illegal use and supporting users.
Law Enforcement
We will disclose your personal data to law enforcement agencies, public authorities or other organizations if legally required to do so, or if such use is reasonably necessary to:
•comply with legal obligation, process or request;
•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 personal data with other companies and organizations for the purposes of fraud protection and credit risk reduction).
Public Profiles
Please note that if your profile is public, your User Content displayed on your profile will be visible to anyone on the App and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings to “Private Account”.
Sale or Merger
We will also disclose your personal data to third parties:•in the event that we sell or buy any business or assets (whether a result of liquidation,bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or•if we sell, buy, merge, or are acquired by other companies or businesses, orsell some or all of our assets. In such transactions, user personal data may beamong the transferred assets.
Cookies
We use or access cookies on your computer or other device (“Cookies”) to automatically collect personal data (e.g.,how you use the App) so as to enable you to log in automatically to our App, enhance your experience using the App, improve our services, and provide you with more thoughtful and personalized services including targeted advertising on the App as well as provide you with services or functions in the App that rely on cookies. You may be able to refuse or disable Cookies by adjusting your browser settings orby setting them on your mobile device. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types ofCookies. If you choose to refuse, disable, or delete Cookies, you may not be able to use the services or functions in the App that rely on these Cookies.
Your Choices
You can access and edit your profile information (e.g., Location, Contact List) by signing into the App. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your photos and videos, send you messages, or post comments to your photos and videos. Should you choose to do so, you may delete your entire account through the App.
The privacy laws that apply to you may give you the right to access, correct,delete or otherwise control how we collect, use or disclose your personal information. To submit a request to exercise such rights, please reach out to us at DPO@dot-passion.com and we willrespond to your request in accordance with applicable law. If you reside inCalifornia, please also see our CCPA Privacy Policy for information about your rights.
Changes to thisPrivacy Policy
We may update this Privacy Policy from time to time. When we update the PrivacyPolicy, we will notify you by updating the “Last Updated” date at the top of the document, posting the new Privacy Policy, and providing any other notice required by applicable law. We may also notify you through the App or by email and, if required by law, we may request your consent before processing your personal data pursuant to such changes. Your continued access to or use of the App after the updated Privacy Policy is effective constitutes your acceptance of the updated policy, and confirmation of your understanding of your rights in relation to your personal data and how we will collect, use, process and disclose it. You should review this Privacy Policy regularly to check for an ysuch updates. If you do not agree to the updated Privacy Policy, you must stop accessing or using the App.
California Notice at Collection
The additional disclosures in this section apply only if you reside in California.These disclosures do not reflect our practices where an exception or exemption applies under the CCPA. Please see the section entitled “What personal data do we collect, use and disclose about you?” above for information about the categories of personal information we collect about you and the purposes for which we collect or use the personal information. The categories of personal information we collect correspond with the following categories under the CCPA’s definitions of “personal information” and “sensitive personal information”:
Categories of "personal information"
o Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
o Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address and telephone number.
o Because we collect photos, audio content and videos from users, we may collect information that reveals characteristics of protected classifications underCalifornia or federal law, including race, color, medical condition, marital status, sex, age, and sexual orientation.
o Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
o Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
o Geolocation data.
o Audio, electronic, visual or similar information.
o We draw inferences from the information we collect about you to create a profile reflecting your preferences and interests.
Categories of "sensitive personal information":
o Account log-in and password.
o Precise geolocation with your permission.
o Because we collect photos, audio content and videos from users, we may collect information that reveals your racial or ethnic origin and religious or philosophical beliefs.
We do not use sensitive personal information to infer characteristics about you, and we only use your sensitive personal information for purposes referred to under Subsection 1798.121(a) of the CCPA.
The criteria we consider in determining how long to retain each category of personal information are as follows. We retain your personal information for as long as it is necessary to provide you with our services. Where we do not need your personal information in order to provide our services to you, we retain it only for so long as we have a legitimate business purpose in keeping such personal information or as may be required by applicable law. There are also occasions where we are likely to keep this personal information for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims. After you have terminated your use of our App, we may delete your personal information from our system, close your App account, and store your personal information in an aggregated or anonymized format.
If you are 16 years of age or above, we may disclose information about you to advertisers, advertising networks and analytics providers to provide you withmore interesting and customized information, promotions and advertising, which is considered “selling” and “sharing” under the CCPA. If you are 15 years ofage or under, we will only do so with affirmative authorization as required by the CCPA. Please note that we do not sell personal information in the sense of exchanging personal information for money. Our CCPA Privacy Policy is available here.
Contact
If you have questions, comments, or requests regarding this Privacy Policy, including any questions on how we use your personal data, or contact our DataProtection Officer at DPO@dot-passion.com.