Effective and last modified May 25, 2018
A. What information does the app obtain and how is it used?
The App typically collects two kinds of information about you: (a) information that you provide that personally identifies you (“PII”); and (b) information that does not personally identify you, which we automatically collect when you use the App or that you provide us (“non-PII”).
1. Personally Identifiable Information (“PII”): Our definition of PII includes any information that may be used to specifically identify or contact you, such as your name, postal address, phone number, etc. As a general policy, we do not automatically collect PII when you access or use the App. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit PII in connection with a feature, program, promotion or some other aspect of our App. For instance, you may: (a) provide your name, postal/shipping address, email address, and phone number when registering with our App, or in connection with a contest entry; (b) provide certain demographic information about you (e.g., age, gender, purchase preference, usage frequency, etc.) when participating in a survey or poll; or (c) post a general comment and/or recommendation on our App. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website. For example, while registration is optional and free, if you do not register you may not be able to use some of the features offered by the App (e.g., downloading extra fonts, art packs, etc.).
2. Non-Personally Identifiable Information (“non-PII”): Our definition of non-PII is any information that does not personally identify you. Non-PII can include certain PII that has been de-identified; that is, information that has been rendered anonymous. We obtain Non-PII about you from information that you provide us, either separately or together with your PII. We also automatically collect certain Non-PII from you when you access our Website. We may also receive non-PII from third party sources. This information can include, but is not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, general geographic information, your mobile operating system, the type of mobile Internet browsers you use, search terms, other applications you have downloaded, and information about the way you use the App.
B. How do we use and share information obtained via the app?
1. PII: The PII you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our parent company, subsidiaries or other affiliated companies (“affiliated companies”), or to communicate with you about content or other information you have posted or shared with us via our App.
2. Non-PII: We use Non-PII in a variety of ways, including to help analyze use of our App, understand customer needs and trends, carry out targeted promotional activities, and to improve our App or services. We may use your Non-PII by itself or aggregate it with information we have obtained from others. We may share your Non-PII with our affiliated companies and third parties to achieve these objectives and others, but remember that none of this information will personally identify or otherwise be tangibly associated with you.
C. Other uses and information
1. Email Communications: In certain instances we may communicate with you via email. For example, we may communicate with you via email if you request a particular service or sign up for a feature that involves email communications, the email relates to a purchase you have made with us, we are sending you information about our other products and services, or you consented to being contacted by email for a particular purpose. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included in most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
2. Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the PII and non-PII we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
3. Extraordinary Circumstances: We reserve the right to disclose any PII or Non-PII about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our App, or other users; or (d) in an emergency to protect the health and safety of our App users or the general public.
4. Your California Privacy Rights: Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain PII as defined under California law during the preceding year for third party direct marketing purposes. Requests are limited to one per calendar year. If you wish to take advantage of and believe you are entitled to the rights afforded under California, your request must attest to the fact that you are a California resident and provide a current California address for our response. We will comply with California law where applicable. You may request the information in writing at firstname.lastname@example.org.
6. Children: The features, programs, promotions and other aspects of our App requiring the submission of PII are not intended for children. We do not knowingly collect PII from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with PII, he/she should contact us at email@example.com. We will delete such information from our files within a reasonable time.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our App. Please be aware that, although we endeavor to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches. In the unfortunate event that your PII (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.
F. Contact and opt-out information
G. EU-U.S. Privacy Shield Framework
Over, Inc. is in the process of self-certifying for Privacy Shield. We intend to abide by the Privacy Shield Principals even before our self-certification process is complete. To that end, Over intends to comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Please see our draft Privacy Shield Policy at https://madewithover.com/privacyshield.
To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.”
H. Sole statement