Voicer Privacy Policy
11/01/2021
Voicer, LLC and its affiliates
(“Company,” “we,” “our,” and/or “us”) value the privacy of individuals who use
our social news applications, the websites where this Privacy Policy is posted ( “Websites”) , and related services (collectively, our
“Services”). This privacy policy (the “Privacy Policy”) explains how we collect,
use, and share information from our users (“Users,” “you,” and/or “your”) to
facilitate your commenting, social news, and influencer networking experience. By
using our Services, you agree to the collection, use, disclosure, and
procedures this Privacy Policy describes. Beyond the Privacy Policy, your use
of our Services is also subject to our
Terms of Service
We neither sell your information to third
parties nor share your information with foreign governments except in the
limited circumstances described in this Privacy Policy (see Section 2
“How
We Share the Information We Collect”
below for more detail).
We recognize that information privacy is
an ongoing responsibility, and so we will from time to time update this Privacy
Policy as we undertake new privacy practices or adopt new privacy policies.
1. Information We Collect
“Personal Information” is information
that identifies, relates to, describes, or can be reasonably
linked to, directly or indirectly, a
particular individual or household. We may collect Personal Information (as we
have done for the past twelve months) from you on or through the Services in a
variety of ways, including when you register on the Services, sign up for
communications, or make any purchases. We also may, from time to time, use
Personal Information about you to improve the Services, and for the various
purposes outlined in this Privacy Policy. Voicer is public and Voicers are
immediately viewable and searchable by anyone around the world. We give you
non-public ways to communicate on Voicer too, through protected Voicers and
Direct Messages. You can also use Voicer under a pseudonym if you prefer not to
use your name.
A.
Information You Provide to Us.
Registration and Basic Account Information
. You don’t have
to create an account to use some of our service features, such as searching and
viewing public Twitter profiles or watching a broadcast on Voicer Events. When
you sign up for an account, we collect Personal
Information you provide to us such as
your name, email address, display name, profile photo,
preferred language, and any Personal
Information you voluntarily provide in your profile
biography.
Verification Information
. If you choose
to go through the verification process, we may ask for
Personal Information that can be used to
verify your identity, such as scans of your government issued photo
identification. When your government-issued photo identification information is
no longer necessary to verify your identity, we delete the scans (front and
back). We retain only an anonymized hash corresponding to the information the
identification document contains, in order to prevent identity theft and
impostor accounts. In addition to the identification information, we may ask
for you to take a selfie for the purpose of preventing impostor accounts. But
they are deleted as soon as they are reviewed as part of the verification
process.
Influencer Network Information.
Unlike other
platforms, Voicer allows you to monetize your content, following, and goodwill.
As part of that, the law requires us to collect certain pieces of Personal
Information. Specifically, in addition to identification information (see above
under
“verification” for our collection and
treatment of identifying information), we collect form W-9 as required by the
IRS. We are required to do this in order to facilitate the receipt by you of
payments earned on Voicer. However, we store that Personal Information in
secure, encrypted form. We never share it, sell it, or use it in any way other
than for purposes of legal compliance. Content you Share. We collect any
information you choose to provide on our Services, such as posts (“Voicers”),
follows, photos, videos, gifs, comments, votes, and echoes.
Payment Information
. If you make a
purchase through our Services, your payment-related Personal Information, such
as your credit and debit card or automated clearing house (ACH) information, is
collected and stored by our third-party payment processor on our behalf.
Communications.
If you contact
us directly, we receive additional Personal Information about you. For example,
if you contact us for customer support, we may receive your name, email address,
phone number, the contents of any message or attachments you may send to us,
and any other information you choose to provide.
Your Contacts
. If you permit
us to access the address book on your device or give us permission to import
your contacts from an email account associated with your account, we may access
and store names and contact information, including Personal Information, from
your address book, to help you follow your contacts, and your contacts to
follow you.
B.
Information We Collect When You Use Our
Services.
We may collect information that may not
reasonably identify you or your household personally, but is linked to your
computer or device (“Device Identifiable Information”). We collect Device Identifiable
Information from you in the normal course of providing the Services. When you
visit our Services to browse, read, or download information, we automatically
collect information about your computer that your browser sends, such as your
IP address, browser type and language, access times, pages visited, and referring
website addresses. We may use Device Identifiable Information to analyze
trends, help administer and improve the Services, to learn about and determine
which pages of the Websites visitors view and for how long, how visitors
navigate throughout the Services, and to gather broad demographic information
for aggregate use. We may also collect Device Identifiable Information through
“cookies” or “web beacons” as explained below.
Device and Location Information
. We receive
Device Identifiable Information about the device and software you use to access
our Services, including IP address (from which approximate or “coarse” location
may be inferred), device type, web browser type, operating system version, phone
carrier and manufacturer, member agents, application installations, device
identifiers, mobile advertising identifiers, and push notification tokens.
Usage Information.
We
automatically receive Device Identifiable Information about your interactions
with our Services, such as the posts or other content you view, the searches
you conduct, the people you follow, and the dates and times of your visits.
Information from Cookies and Similar
Technologies.
We may collect information using cookies, pixel tags, and
similar technologies. Cookies are small text files containing a string of alphanumeric
characters. We may use both session cookies and persistent cookies. A session
cookie disappears after you close your browser. A persistent cookie remains
after you close your browser and may be used by your browser on subsequent
visits to our Services.
Cookies operate in the background and you
can turn them off by adjusting your Web browser settings, but doing so may make
it difficult to use some of the features on the Websites or the features may
not be available to you. We may use cookies to make your Service experience
easier by, for example, remembering your preferences, or keeping track of your
login name and password. For more information on your choices regarding
cookies, you can review the FTC’s guide to opting out of online tracking for
computers and mobile devices. Your browser may offer you a “Do Not Track”
option, which allows you to signal to operators of websites and web
applications and services that you do not want them to track your online
activities. The Services do not currently support Do Not Track requests.
2. How We Use the Information We Collect
We may use the Personal Information we
collect:
• To fulfill or meet requirements
inherent in the reason you provided the information. For example, we use the
information about who you follow on Voicer to deliver you a feed of Voicers
from those accounts; we use the information you put into a Voicers to display
it to those who follow you or users who echo your Voircers,
or who visit your profile on Voicer;
• To create, customize, and secure your
account for use of the Services;
• To provide, maintain, and improve our
Services, including for testing, research, analysis and product development;
• To personalize your experience on our Services,
such as by providing tailored content and recommendations;
• To understand and analyze how you use
our Services and develop new products, services, features, and/or
functionality;
• To communicate with you, provide you
with updates and other information relating to our Services, provide
information that you request, respond to comments and questions, and otherwise
provide customer support;
• For marketing and advertising purposes,
such as developing and providing promotional and advertising materials that may
be relevant, valuable or otherwise of interest to you, including providing you
with targeted offers and ads through our Website, and
via email or text message (with your consent, where required by law);
• To send you text messages and push
notifications;
• To facilitate transactions,
redemptions, and payments;
• To verify your identity and determine
your eligibility to join our influencer network;
• To find and prevent fraud and respond
to trust and safety issues;
• To evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or transfer
of some or all of our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Information held by us about
our consumers is among the assets transferred;
• To help maintain the safety, security,
and integrity of our Website, products and services, databases
and other technology assets, and business;
• For compliance purposes, including
enforcing our Terms of Service or other legal rights, or as may be required by
applicable laws and regulations or requested by any judicial process, law
enforcement or governmental agency; and
• For other purposes for which we provide
specific notice at the time the information is collected. We will not collect
additional categories of Personal Information or use the Personal Information we
collected for materially different, unrelated, or incompatible purposes without
updating this Privacy Policy to provide you with notice as set out in Section
10 “Changes to the Privacy Policy” below.
3. How We Share the Information We Collect
Vendors and Service Providers.
We may share
any Personal Information we receive with vendors and service providers retained
in connection with the provision of our Services.
Content you Share.
Our Services
are social services which allow you to find, enjoy, and share content. Your
name, display name, profile photo, about me section, and contacts (i.e., members
you are following) will always be viewable and/or searchable by other Members.
The content you post to our Services will be displayed and viewable by other
Members by default. Although this content is public by default, in the “Your
Choices” section below, we describe the account settings and controls you can
use to limit the sharing of certain information. We are not responsible for
other Members’ use of available information, so you should carefully consider
whether and what to post and how you identify yourself on our Services.
Marketing.
We do not
share Personal Information about you with nonaffiliated third parties for their
direct marketing purposes unless we have your affirmative express consent.
As Required By
Law and Similar Disclosures
. We may access, preserve, and disclose
your Personal Information if we believe doing so is required or appropriate to:
(a) comply with law enforcement requests and legal process, such as a court
order or subpoena; (b) respond to your requests; or (c) protect your, our, or
others’ rights, property, or safety. For the avoidance of doubt, the disclosure
of your Personal Information may occur if you post any objectionable content on
or through our Services.
Merger, Sale, or Other Asset Transfers.
We may transfer
your Personal Information to service providers, advisors, potential
transactional partners, or other third parties in connection with the consideration,
negotiation, or completion of a corporate transaction in which we are acquired
by or merged with another company or we sell, liquidate, or transfer all or a
portion of our assets. The use of your Personal Information following any of
these events will be governed by the provisions of this Privacy Policy in
effect at the time of the acquisition or merger.
Consent.
We may also
disclose your Personal Information with your permission.
4. Your Choices
Sharing Preferences
. We provide
you with settings to allow you to set your sharing preferences for content you
post to our Services. Certain Personal Information, such as your display name, may
always be publicly available to others, and other Personal Information is made
publicly available to others by default. To change whether certain information
is publicly viewable, you can adjust the settings in your account.
Marketing Communications.
We send you
marketing communications consistent with your choices. You can unsubscribe from
our promotional emails by adjusting your account settings or via the link
provided in the emails. Even if you opt-out of receiving promotional messages
from us, you will continue to receive administrative messages from us.
Notifications.
You can
opt-out of receiving notifications for posts, votes, echoes, comments, and followers
by adjusting your profile and/or operating system (i.e., iOS or Android)
settings. Correction. You may correct your Personal Information at any time by
logging in to your account and updating any inaccurate information.
Additional Privacy Rights.
In addition,
if you are a resident of California or of the European Economic Area, you have
additional rights with respect to your Personal Information. Please see Sections
11 and 12 below for additional information.
5. Third Party Links and Sites
Our Services may contain links to other
websites, products, or services that we do not own or operate. We are not
responsible for the privacy practices of these third parties. Please be aware that
this Privacy Policy does not apply to your activities on these third-party
services or any information you disclose to these third parties. We encourage
you to read their privacy policies before providing any information to them.
For example, any information you share
with Google as a consequence of sharing or interacting with YouTube content on Voicer
is governed by Google’s privacy policy.
Google now provides users some control over the collection of data by its users
and API Clients like Voicer;
follow this link for more
information on revoking
an API client’s access to your data. Exercising such control may require having
a Google account, which itself may be a privacy concern for some of our
members. Therefore, members are encouraged to use Voicer’s own native video
capabilities (or the capabilities of other platforms equally respectful of
member privacy) if they wish to avoid sharing data with Google. (A similar
disclaimer applies to Rumble, an emerging competitor of Google-YouTube. When in
doubt, consult the privacy policy of the entity responsible for facilitating
the display of content on our Services, before choosing to interact with it, so
you can make an informed decision about your privacy.)
6. Security
We make reasonable efforts to protect
your Personal Information by using physical and electronic safeguards designed
to improve the security of the Personal Information we maintain. However, no
method of transmission or storage of data is 100% secure and we will not be
responsible for any damage that results from a security breach of data or the
unauthorized access to or use of information, whether Personal Information or
Device Identifiable Information. To the extent we provide your Personal
Information to any third parties, we will request that they use reasonable security
measures to protect your information.
7. Children’s Data
We do not knowingly collect, maintain, or
use Personal Information from children under 13 years of age, and no part of
our Services is directed to children. If you learn that a child has provided us
with Personal Information in violation of this Privacy Policy, then you may
alert us at privacy@Voicer.net and we will delete such information.
8. International Transfers of Data
Our Services are hosted in the United
States and intended for visitors located within the United States. If you
choose to use our Services from the European Union or other regions of the
world with laws governing data collection and use that may differ from U.S.
law, then please note that you are transferring your Personal Information
outside of those regions to the United States for storage and processing. By
providing any information, including Personal Information, on or to our
Services, you consent to such transfer, storage, and processing.
9. Update or Delete Your Information
You can update your account and profile
information through your account settings. You can delete your account by
selecting that option via
our online Voicer
Privacy Request portal, which is accessible by clicking here.
10. Changes to the Privacy Policy
We will post any adjustments to the
Privacy Policy on this page, and the revised version will be effective when it
is posted. If we materially change the ways in which we use or share Personal Information
previously collected from you through our Services, we will notify you through
our Services, by email, or other communication.
Your continued use of our
Services following our posting or notifying you of changes constitutes your
acceptance of such changes
.
11. Additional Rights in California: Your
California Privacy Rights
If you are a California resident, the
California Consumer Privacy Act of 2018 (“CCPA”) provides you with additional
rights regarding our use of your Personal Information. Note that Personal Information
does not include publicly available information from government records, deidentified
or aggregated consumer information, or information excluded from the CCPA’s scope.
The CCPA protects the following categories of Personal Information, and for
your convenience, we have provided the following chart summarizing what
categories we collect as another way of covering the information set forth in
Section 1 “Information We Collect”:
Category
|
Examples |
Collected |
1. Identifiers |
A real name, alias, postal address,
unique personal identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number, driver’s license number,
passport
number, or other similar identifiers.
|
Some items. See Section 1
“Information We Collect” for
more details. |
2. Personal information
categories listed in the California
Customer Records statute (Cal.
Civ. Code § 1798.80(e)) |
A name, signature, Social Security
number, physical characteristics or description,
address, telephone number, passport
number, driver’s license or state identification card number, insurance
policy number, education, employment,
employment history, bank account
number, credit card number, debit card
number, or any other financial information,
medical information, or health
insurance information.
Some personal information included in
this category may overlap with other categories
|
Some items. See Section 1
“Information We Collect” for
more details. |
3. Protected classification
characteristics under California or
federal law. |
Age (40 years or older), race, color,
ancestry, national origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex
(Including gender, gender identity,
gender expression, pregnancy or childbirth and
related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information). |
Only if you choose to provide it
in the verification process or in
user-generated content (such as
uploading an image or video sharing
this information, or including in a bio), but this information is not
analyzed. |
4. Commercial information |
Records of personal property, products
or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies. |
Only records of (1) device type
used in connection with your account,
and (2) purchases of
ads on Voicer (if applicable). |
5. Biometric information |
Genetic, physiological, behavioral, and
biological characteristics, or activity
patterns used to extract a template or
other identifier or identifying information, such as, fingerprints,
faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data. |
Only if you choose to provide it
in user-generated content (such
as uploading an image or video
sharing this information, or including
in a bio), but the
information is analyzed only for
compliance with applicable law and as
described in our Guidelines Enforcement Process
|
Category
|
Examples
|
Collected
|
6. Internet or other similar
network activity. |
Browsing history, search history,
information on a consumer’s
interaction with a website,
application, or advertisement.
|
See Section 1(B) to learn more
about how some of these items
may be collected and used |
7. Geolocation data. |
Physical location or movements
including e.g., IP address information.
|
Only coarse location data inferred from
IP address. |
8. Sensory data. |
Audio, electronic, visual, thermal,
olfactory, or similar information.
|
Only if using device to capture,
audio, photo or video with the
Services as part of user generated
content. |
9. Professional or employment related
information. |
Current or past job history or performance
evaluations.
|
Only if you choose to provide it
in user-generated content, for
example a Voicers, your profile bio, or
display name. But this information is not further analyzed. |
10. Non-public education
information (per the Family
Educational Rights and Privacy Act (20
U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a
student maintained by an educational institution or party acting on its
behalf, such
as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or
student
disciplinary records.
|
Only if you choose to provide it
in user-generated content, for
example a Voicers, your profile
bio, or display name. But this information
is not analyzed.
|
11. Inferences drawn from other Personal
Information. |
Profile reflecting a person’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes. |
No |
All of the categories collected above may
be provided to third parties as described in Section 3
“How We Share the Information We
Collect”.
A.
Your Rights and Choices under the CCPA.
The CCPA provides consumers (California
residents) with specific rights regarding their Personal
Information. This section describes your
CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we
disclose certain information to you about our collection and
use of your Personal Information over the
past 12 months (the “right to know”). Once we receive
your request and confirm your identity
(see the “Exercising Your Rights to Know or Delete”
subsection below), we will disclose to
you:
• The categories of Personal Information
we collected about you.
• The categories of sources for the
Personal Information we collected about you.
• Our business or commercial purpose for
collecting that Personal Information.
• The categories of third parties with
whom we share that Personal Information.
• If we disclosed your Personal
Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal
Information categories that each category of recipient purchased; and
disclosures for a business purpose,
identifying the Personal Information categories that each category of recipient
obtained.
• The specific pieces of Personal
Information we collected about you (also called a “data portability request”).
Right to Delete
You have the right to request that we
delete any of your Personal Information that we have collected and retained,
subject to certain exceptions (the “right to delete”). Once we receive your
request and confirm your identity (see “
Exercising Your Rights to Know or
Delete”
), we will review your request to see if an applicable exception
allows us to retain the information. We may deny your deletion request if
retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we
collected the Personal Information, provide a good or service that you
requested, take actions reasonably anticipated within the context of our ongoing
business relationship with you, fulfill the terms of a written warranty or
product recall conducted in accordance with federal law, or otherwise perform
our contract with you
• Detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities.
• Debug products to identify and repair
errors that impair existing intended functionality.
• Exercise Social Blogging, ensure the right
of another consumer to exercise their Social Blogging rights, or exercise another
right provided for by law.
• Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are
reasonably aligned with consumer expectations based on your relationship with
us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that
information that are compatible with the context in which you provided it.
We will delete or deidentify Personal
Information not subject to one of these exceptions from our records and will
direct our service providers to take similar action.
Exercising
Your Rights to Know or Delete
To exercise your rights to know or delete
described above, please submit a request via
our
online Voicer Privacy Request portal, which is accessible by clicking here.
Only you, or someone legally authorized
to act on your behalf, may make a request to know or delete related to your
Personal Information by submitting proof of identity and, in the case of someone
legally authorized to act on your behalf, proof of their authority to act.
You may also make a request to know or
delete on behalf of your child by providing proof of identity.
You may submit a request to know only
twice within a 12-month period. Your request to know or delete must provide
information sufficient for us to reasonably verify you are the person about whom
we collected Personal Information (or you are an authorized representative of
same), as well as describe your request with enough detail for us to properly
understand, evaluate, and respond to it. We cannot respond to your request or
provide you with Personal Information if we cannot verify your identity or
authority to make the request and confirm the Personal Information relates to
you.
You do not need to create an account with
us to submit a request to know or delete. We will use Personal Information
provided in the request only to verify the requestor’s identity or authority to
make it.
For instructions on exercising your sale
opt-out or opt-in rights, see
“Personal Information Sales Opt-Out and Opt-In
Rights”
below.
Response
Timing and Format
We will confirm receipt of your request
within ten (10) business days. If you do not receive confirmation within the
10-day timeframe, please contact us at
privacy@Voicer.net
.
We endeavor to substantively respond to a
verifiable consumer request within forty-five (45) days of its receipt. If we
require more time (up to another 45 days), we will inform you of the reason and
extension period in writing.
If you have an account with us, we will
deliver our written response to that account, or to the email address
associated with the account. If you do not have an account with us, we will
deliver our written response by mail or electronically, at your option.
Any disclosures we provide will cover the
12-month period preceding our receipt of your request. The response we provide
will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your Personal
Information that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance.
We do not charge a fee to process or
respond to your verifiable consumer request unless it is excessive, repetitive,
or manifestly unfounded. If we determine that the request warrants a fee, we will
tell you why we made that decision and provide you with a cost estimate before
completing your request.
Personal
Information Sales Opt-Out and Opt-In Rights
The CCPA prohibits a business from
selling Personal Information unless you have received explicit notice and an
opportunity to opt out of further sales. We do not sell your Personal
Information to third parties. If this position changes and you are older than
16, you will be given explicit notice and an opportunity to opt out of further
sales, with details of how to exercise that “right to opt out” listed in this
policy.
We do not sell the Personal Information
of any consumer, including consumers we actually know are less than 16 years
old, unless we receive affirmative authorization (the “right to opt in”) from either
the consumer who is between 13 and 15 years old, or the parent or guardian of a
consumer less than 13 years old. Consumers who opt in to Personal Information
sales may opt out of future sales at any time.
We will only use Personal Information
provided in an opt-out request to review and comply with the request.
B.
Non-Discrimination under the CCPA.
We will not discriminate against you for
exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates
for goods or services, including through granting
discounts or other benefits, or imposing
penalties.
• Provide you a different level or
quality of goods or services.
• Suggest that you may receive a
different price or rate for goods or services or a
different level or quality of goods or
services.
However, we may offer you certain
financial incentives permitted by the CCPA that can result in different prices,
rates, or quality levels. Any CCPA-permitted financial incentive we offer will
reasonably relate to your Personal Information’s value and contain written
terms that describe the program’s material aspects. Participation in a
financial incentive program requires your prior opt-in consent, which you may
revoke at any time.
C.
Other California Privacy Rights
.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. Not all information sharing is covered by the “Shine The Light” requirements and only information on covered sharing may be included in our response. To make such a request, please do so via our online Voicer Privacy Request Form, which is accessible by clicking here.
Voicer, LLC is the data controller with
respect to processing of your Personal Information in connection with the
Services.
13. Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@Voicer.net
Please note that emails to
privacy@Voicer.net
should include only
questions, comments, or concerns regarding our processing activities. To make a
request for access or deletion of your Personal Information as permitted by
law, please submit a request via
our online
Voicer Privacy Request Form, which is accessible by clicking here.
Last Updated: November, 2021